ADA Transition Plan - El Paso County, TexasADA Transition Plan 0 ADA Transition Plan 2017 2017...

ADA Transition Plan

0

ADA Transition Plan

2017

2017 UPDATE

AMANDA PROFFITT

EL PASO COUNTY | [Company address]

REVISED NOVEMBER 2017 1

ADA TRANSITION PLAN

Contents INTRODUCTION ............................................................................................................................................. 4

LEGAL MANDATE .......................................................................................................................................... 7

Americans with Disabilities Act ................................................................................................................. 7

1. Establishment of ADA disability Services and ADA Coordinator ....................................................... 8

2. Issue of Notice of ADA Requirement ................................................................................................ 8

3. Establishment of Grievance Procedures ........................................................................................... 8

4. Conduct Self Evaluation .................................................................................................................... 8

a. Policies and Procedures ................................................................................................................ 9

b. Communications ........................................................................................................................... 9

c. Employment .................................................................................................................................. 9

d. Program Facility Accessibility ........................................................................................................ 9

5. Develop a Transition Plan ................................................................................................................. 9

Americans with Disabilities Act Accessible Guidelines (ADAAG) ............................................................ 10

Texas Accessibility Standards .................................................................................................................. 10

METHODOLOGY .......................................................................................................................................... 11

Phase I: Planning and Self Evaluation ..................................................................................................... 11

ADA Coordinator ................................................................................................................................. 11

A. Facility Inventory ......................................................................................................................... 12

B. Survey Tools ................................................................................................................................ 12

1. Exterior Accessibility ................................................................................................................... 12

2. Interior Accessibility .................................................................................................................... 13

3. Program Accessibility .................................................................................................................. 13

Self-Evaluation/Data Collection .............................................................................................................. 14

A. Establishment of Disability Services and Position of ADA Coordinator ...................................... 14

B. Issue Notice of ADA Requirements ............................................................................................. 15

C. Grievance Procedures for County Services, Programs, and Activities ........................................ 15

D. Policies and Procedures Review ................................................................................................. 16

E. ADA Communications Review ..................................................................................................... 17

F. Employment Policies and Practices Review ................................................................................ 18

Phase II: Recommendations and Prioritization ....................................................................................... 19

Data Analysis ....................................................................................................................................... 19

Policy and Procedures Survey and Recommendations ....................................................................... 19


ADA TRANSITION PLAN

Communications Survey and Recommendations ............................................................................... 19

A. Auxiliary Aids and Services .......................................................................................................... 20

B. Sign Language Interpreter Services............................................................................................. 20

C. Telecommunications Access ....................................................................................................... 21

D. Inclusion of Braille Services in County Agencies ......................................................................... 22

Employment Recommendations ......................................................................................................... 22

Priority System Development ............................................................................................................. 22

Priority One: ........................................................................................................................................ 23

Priority Two: ........................................................................................................................................ 23

Priority Three: ..................................................................................................................................... 23

Priority 1: Accessible Entrance into Facility: ....................................................................................... 23

Priority 2: Access to Goods and Services: ........................................................................................... 23

Priority 3: Access to Restrooms: ......................................................................................................... 24

Priority 4: Any Other Measures Necessary: ........................................................................................ 24

Operational, Non-Structural and Structural Recommendations ........................................................ 24

Operational ......................................................................................................................................... 24

Non-Structural..................................................................................................................................... 24

Structural ............................................................................................................................................ 25

Website ............................................................................................................................................... 25

Budget ................................................................................................................................................. 25

Community Involvement and Outreach ............................................................................................. 25

Phase III: Adoption and Implementation ................................................................................................ 26

Public Outreach ................................................................................................................................... 26

Training ............................................................................................................................................... 27

BUILDINGS REVIEWED ................................................................................................................................ 27

PARTIAL BUILDINGS REVIEWED .................................................................................................................. 28

BUILDINGS CORRECTED .............................................................................................................................. 28

PARTIAL BUILDINGS CORRECTED ................................................................................................................ 28

PARKS REVIEWED ........................................................................................................................................ 29

PARKS CORRECTED ...................................................................................................................................... 29

PARTIAL PARKS CORRECTED ....................................................................................................................... 29

SUMMARY ................................................................................................................................................... 30

RECOMMENDATIONS ................................................................................................................................. 31


ADA TRANSITION PLAN

ATTACHMENTS ............................................................................................................................................ 32

Attachment I: Facility Inventory ............................................................................................................. 33

Attachment II: Surveys ............................................................................................................................ 39

Attachment III: Policies and Practices Survey ....................................................................................... 118

Attachment IV: Communications Access Survey .................................................................................. 125

Attachment V: ADA Coordinator Job Description ................................................................................. 131

Attachment VI: Grievance Procedures.................................................................................................. 140

Attachment VII: Reasonable Accommodations Request ...................................................................... 144

Attachment VIII: Reasonable Modifications ......................................................................................... 147

Attachment IX: Notice under Americans with Disabilities Act ............................................................. 150


ADA TRANSITION PLAN

INTRODUCTION

The Americans with Disabilities Act (ADA) of 1990 provides comprehensive civil rights

protections to qualified individuals with disabilities in the areas of employment, public

accommodations, state and local government services, and telecommunications. A primary goal

of the ADA is to ensure equal participation in public life for all Americans with disabilities.

The ADA is comprised of 5 titles: Title I employment, Title II public entities, Title III Public

accommodations, Title IV telecommunications, and Title V miscellaneous provisions.

This transition plan will cover Title II requirements. Under Title II, a public entity may not deny

the benefits of its programs, activities, or services to individuals with disabilities by maintaining

inaccessible facilities. A public entity’s programs, services, and activities, when viewed in their

entirety, must be made readily accessible to and usable by individuals with disabilities, except

where to do so would result in a fundamental alteration in the nature of the program; result in

undue financial and administrative burdens or threaten or destroy the historic significance of a

historic property. This standard, known as “program accessibility” applies to all existing facilities

of a public entity. Under this standard, the County is not required to make all of its existing

facilities or every part of a single facility accessible.

The State of Texas has developed its own set of barrier removal standards which follow the

ADAAG closely. The Texas Accessibility Standards (TAS) expand the ADAAG with additional

state scoping requirements and standards. The TAS brings the states Architectural Barriers Act

into alignment with the requirements of the ADA. The TAS encourages compliance by using

common standards and speeds the dissemination of required standards to owners, design

professionals and related user groups. The TAS is a construction law and only applies to new

construction, additions, or buildings being remodeled.

Program accessibility may be achieved by a number of methods, including but not limited to:

alteration of existing facilities to remove architectural barriers, the relocation of activities or

services from inaccessible to accessible buildings, the redesign of equipment, and assignment of

aides to beneficiaries, home visits, or delivery of services at alternate accessible sites. When

choosing a method of providing program access, priority is to be given to the one that results in

the most integrated setting appropriate to encourage interaction among all users, including

individuals with disabilities.

Title 28 CFR Part 35, Non Discrimination on the Basis of Disability in State and Local

Government Services, outlines the requirements for a Transition Plan. Where physical

modifications are necessary to achieve program accessibility, a public entity with 50 or more

employees must develop a Transition Plan. Transition Plans must provide the steps necessary to

complete such facility modifications. The removal of all physical barriers identified in the Plan

must be completed as expeditiously as possible.


ADA TRANSITION PLAN

This Transition Plan documents the access barriers for the exterior and interior site of

approximately 56 County buildings and 15 County parks. The Transition Plan includes a schedule

of how these facilities will be evaluated over the next several years. The documented access

barriers indicate that existing building and park conditions deviate from current State and Federal

standards for new construction. For each barrier, this Transition Plan outlines the code deviations

and requirements from the ADA Accessibility Guidelines (ADAAG) as well as the Texas

Accessibility Standards (TAS).

To comply with the government standards for accessibility to County services, programs, and

activities, this Transition Plan:

Identifies physical obstacles in the facilities that limit the accessibility of its programs or

activities to individuals with disabilities;

Assesses the extent of architectural barriers to program accessibility on site and within

the buildings operated by the County,

Sets priorities for barrier elimination,

Indicates the official responsible for implementation of the each facilities transition plan.

Experience indicates compliance activities are best approached in a coordinated manner.

Furthermore, success in implementing permanent changes depends to great extent on the quality

of the planning process itself and the degree to which compliance becomes integrated in on-going

operations.

The ADA Transition Plan process consists of three phases:

Phase I: Planning and Self-Evaluation Phase:

The first phase involved planning and assessment, including the formation of the ADA

Coordinator position, grievance procedures, the facility inventory, the creation of survey

tools, and the hiring of the ADA Coordinator. Part II of Phase I includes the subsequent

data collection of all County facilities. This is and will be an ongoing portion of Phase I.

Phase II: Recommendations and Prioritization:

Review of Phase I Part II findings and the development of recommendations on the

selected facilities for the year.

Phase III: Adoption and Implementation:

Phase III includes the approval of recommended actions by the County of El Paso

Commissioners Court, the start of implementation of the ADA Transition Plan,

evaluation of recommendations during and after the implementation process, and review

and update of the Transition Plan.


ADA TRANSITION PLAN

During Phase I of the ADA Transition Plan process, the Human Resources Department and the

ADA Coordinator completed reviews of the County’s policies and procedures, communication

resources, and County programs and facilities assigned for the time period. Grievance procedures

have been created and made available on line.

A facilities list of all county owned, operated, and leased buildings and parks was created to help

with the self-evaluation of all County facilities. Redesigned survey tools help with the self-

evaluation and help maintain the integrity of the Transition Plan. The survey tools give step by

step instructions from the starting point of the evaluation to the ending point and what needs to be

addressed in each facility. Due to the number of facilities the County owns and leases and the

number of staff available to conduct the self-assessment reviews, it was decided that only a few

facilities could be inspected each year. The number is subject to change each year depending on

the size of the facility. A minimum number was set of 5 buildings and 2 parks and or programs per

year.

A major factor in the implementation of the Transition Plan for the first year was a requirement to

bring Ascarate Park into compliance with the ADAAG and the TAS per an agreement made

between the County of El Paso and Deseret ADAPT. The self-assessment of the park was

completed and a report was developed. The Ascarate Park project was finished in 2012, and meets

all the requirements of the agreement the County of El Paso Signed with Desert ADAPT. Phase I

Part II also included the evaluation of the following facilities between 2012 and 2014: Gallegos

Park, Agua Dolce Park, Montana Vista Park, San Elizario Placita, Sparks Park, Westway Park,

The tax office, Liberty Hall, The County Court House, Adult Probation #4, Sheriff’s Office annex

at Sparks, Juvenile Probation Department, MDR Building, North East Annex, North West Annex,

Parking Garage 1, and Parking Garage 2. The following facilities were inspected between 2015

and 2017: Sparks Sheriff Department Annex, Ysleta Annex Building A-1, Sports Park restrooms,

Sports Park parking area, Tax Office at Ascarate Park, Socorro Road Bus Stops, The East Side

Annex, Justice of the Peace #1, Justice of the Peace #5, Alejandra Flores Park, Risinger Park, San

Felipe Park, The Sports Park, and Ted Richardson Park.

Phase II focuses on the development of recommendations for ensuring accessibility to County

programs and the assessed facilities. A detailed analysis of the data collected, for the selected

facilities during Phase I, was analyzed and recommendations were developed to correct identified

deficiencies in each of the four major areas. In addition, cost estimates for removing barriers were

generated by the appropriate County facility management agencies.

During Phase III, the ADA Transition Plan was approved by the County of El Paso

Commissioners Court in 2012, recommendations developed during Phase II to bring the County

into compliance with the Americans with Disabilities Act and the Texas Accessibility Standards

are being implemented. The Transition Plan was updated and approved in 2015 and continues to

be implemented county wide. The Transition Plan was updated and implemented in 2017.


ADA TRANSITION PLAN

Public outreach, accountability, and transparency are all crucial to the success of the ADA

transition plan. The use of technology, by having grievance procedures online, has helped the

county achieve these goals. Public outreach has been important from the outset of planning.

Knowing only a few facilities a year would be self-assessed, it was important for the County to get

feedback on the public’s opinion on priority facilities. Meetings were held in each of the four

precincts in 2012. Attendance for these meetings were low, but the feedback we received was

valuable. The ADA Coordinator was able to get started on the most important buildings to the

citizens of El Paso County.

Phase III implementation of the recommendations have included a considerable emphasis on

broad-based training of County staff on ADA and sensitivity. Public outreach will continue

throughout the transition plan. During the implementation process a review of progress will be

made to all facilities, after a facility is complete a final assessment will be made to confirm l

recommendations were effectively and correctly implemented.

The County of El Paso and its Court of County Commissioners are demonstrating, through this

Transition Plan, their commitment to inclusion of all County citizens in public programs and

facilities, as well as dedication to transparency in government and to sustaining a high quality of

life for residents. The institution of an ongoing ADA compliance monitoring system, coupled with

increased community outreach and involvement, will ensure that the County of El Paso will be a

leader in the effort to comply with the Americans with Disabilities Act and Texas Accessibility

Standards, and continue the County’s commitment to inclusion.

As the County moves through the Transition Plan process, estimates of the cost to bring each

program, park, and building into full compliance with the ADA and TAS in terms of programs and

facilities will be provided.

LEGAL MANDATE

Americans with Disabilities Act

The Americans with Disabilities Act (ADA) was signed into law on July 26, 1990, and provides a

comprehensive mandate of the rights of individuals with disabilities. The signing of the ADA into

law was a momentous public policy initiative, because approximately 20% of all Americans (about

54 million people) have some type of disability that affects their daily lives. The ADA has three

titles that address information pertaining to employment and the accessibility of programs,

services, and facilities.

Title II of the ADA covers public entities including El Paso County Government and all its

programs, services, and activities. The regulations contained in Title II of the Americans with

Disabilities Act prohibit public entities from discriminating against or excluding individuals with

disabilities from programs, services, or activities on the basis of disability.


ADA TRANSITION PLAN

The provisions of Title II fall into four broad areas:

1. General non-discrimination

2. Equal effective communication

3. Employment

4. Program and facility accessibility

Equal opportunity must be provided through reasonable modification in policies, practices, or

procedures; effective communication must be ensured through the provisions of auxiliary aids and

services; nondiscriminatory employment practices are required; and programs must be made

accessible through programmatic or architectural modifications.

Title II of the ADA requires that public entities take systematic steps to examine their programs

and establish a plan for ensuring compliance with the law. Five action steps must be taken to bring

a public entity into compliance with Title II regulations:

1. Establishment of ADA disability Services and ADA Coordinator

The ADA requires a public entity with fifty or more employees to designate at least

one employee to coordinate ADA compliance. Section 35.107 (a)

2. Issue of Notice of ADA Requirement

All public entities, regardless of size, must provide information to applicants,

participants, beneficiaries, employees, and other interested parties regarding the rights

and protections afforded by Title II of the ADA, including information about how the

Title II requirements apply to its particular programs, services, and activities. This

notice also serves to notify the public of the ADA Coordinator’s contact information.

This notice is sent every two years to department directors. Section 35.106.

3. Establishment of Grievance Procedures

Public entities with fifty or more employees must adopt and publish grievance

procedures providing for prompt and equitable resolution of grievances arising under

Title II of the ADA. The purpose of this grievance is to provide a mechanism for

resolution of discrimination issues at the County level, rather than requiring the

complainant to resort to the federal complaint process. Section 35.107 (b)

4. Conduct Self Evaluation

A self-evaluation is a comprehensive review of the following four major areas: Section

35.105.


ADA TRANSITION PLAN

a. Policies and Procedures

The self-evaluation involves through review of general policies and procedures

to ensure non-discrimination.

b. Communications

The purpose of this survey is to assess the County’s ability to provide

communication for individuals with disabilities that is as effective as the

communication provided to individuals without disabilities.

c. Employment

The County does not discriminate on the basis of disability in its hiring or

employment practices and complies with all regulations promulgated by the

U.S. Equal Employment Opportunity Commission under Title I of the

Americans with Disabilities Act (ADA).

d. Program Facility Accessibility

Title II of the ADA prohibits public entities from excluding individuals with

disabilities from programs, services, or activities because of inaccessible

facilities. In order to ensure that our programs are accessible, when viewed in

their entirety, we are required to conduct a facility access review.

5. Develop a Transition Plan

The ADA Transition Plan flows logically from Self-Evaluation. If the self-evaluation

for programs and facilities reveals that barriers cannot be removed through

nonstructural program changes, Title II requires that public entities develop a transition

plan. The regulation requires that, at a minimum, the transition plan:

a. List physical obstacles that limit the accessibility of the public entity’s

programs, services, or activities to people with disabilities;

b. Describe the methods to be used to make the facilities accessible;

c. Provide cost estimates;

d. Provide a schedule for making the access modifications – a yearly schedule for

making the modifications if the transition plan is more than one year long;


ADA TRANSITION PLAN

e. Name a person responsible for implementation of the transition plan.

In addition, Section 35.150 (d)(2) requires that if the public entity has responsibility or

authority over streets, roads or walkways, its transition plan shall include a schedule

for providing curb ramps or other sloped areas where pedestrian walks cross curbs.

The ADA does not require a public entity to take any action that it can demonstrate

would result in a fundamental alteration in the nature of a program or activity, would

create a hazardous condition for other people, or would represent an undue financial

and administrative burden.

Americans with Disabilities Act Accessible Guidelines (ADAAG)

The Americans with Disabilities Act Accessible Guidelines (ADAAG) sets guidelines for

accessibility to places of public accommodation and commercial facilities by individuals with

disabilities. These guidelines are to be applied during the design, construction, and alteration of

such buildings and facilities to the extent required by regulations issued by Federal agencies,

including the Department of Justice, under the Americans with Disabilities Act of 1990.

Texas Accessibility Standards

The Texas Accessibility Standards (TAS) sets standards for accessibility to: public buildings and

facilities, privately owned buildings and facilities leased or occupied by state agencies; places of

public accommodation; and commercial facilities by individuals with disabilities.

These standards are applied during the design, construction, and alteration of such buildings and

facilities to the extent required by regulations issued by the Texas Department of Licensing and

Regulation, under the Architectural Barriers Act, codified as Article 9102, Texas Civil Statutes.

These Standards closely follow the Americans with Disabilities Act Accessibility Guidelines

(ADAAG), and are intended to facilitate equivalency certification of the state program for the

elimination of architectural barriers by the United States Department of Justice by:

1. Bringing the State Architectural Barriers Act into alignment with the requirements of

the Americans with Disabilities Act.

2. Expanding ADAAG with additional state scoping requirements and standards.

3. Encouraging compliance by using common standards.

4. Speeding the dissemination of required standards to owners, design professionals, and

related user groups.


ADA TRANSITION PLAN

METHODOLOGY

ADA compliance is a complex process that affects the entity at many levels. Experience indicates

compliance activities are best approached in a coordinated manner. Furthermore, success in

implementing permanent changes depends to a great extent on the quality of the planning process

itself and the degree to which compliance becomes integrated in on-going operations.

The County of El Paso’s Transition Plan process has been organized into three main phases which

incorporate the five general requirements of Title II regulations.

Phase I: Planning and Self-Evaluation Phase – Phase I of the Transition Plan includes the

following activities:

Planning and assessment

Formation of the ADA Coordinator Position

Facility Inventory

Creation of Survey Tools

Hiring of an ADA Coordinator

Data Collection

Phase II: Recommendations and Prioritization – Phase II of the Transition Plan included

includes the following activities:

Data Analysis;

Development of program/facility recommendations and priority system;

Cost estimate by facility management agencies;

Community involvement and outreach.

Phase III: Adoption and Implementation – Phase III of the Transition Plan includes the

following:

Approval of recommended action by the County of El Paso’s Commissioners Court

Implementation of the ADA Transition Plan

Phase I: Planning and Self Evaluation

ADA Coordinator

In May 2011, the County Commissioners directed the establishment of the ADA

Coordinator position to develop and implement a county wide transition plan. The ADA

Coordinator with help from County staff members will carry the project through the initial

reviews, through the analysis phase, and will be instrumental in the implementation phase

over the next several years. This will ensure that ADA compliance is priority, and staff and

resources are mobilized to meet the need.


ADA TRANSITION PLAN

After reviewing the outcome of the survey of Ascarate Park, a process was put in place on

how all future surveys will be conducted. A report was generated from this survey and

given to the department directors concerned with Ascarate Park. This set the example on

all future surveys and reports for the remainder of facilities and parks within the County.

This format will keep the integrity of the plan while being efficient and making sure

progress is made throughout the County’s facilities. As we have made progress through

some of the County’s facilities, improvements have been made to the formatting and the

review procedures, making the process more efficient.

A. Facility Inventory

The facility inventory is a management tool for organizing and monitoring

access reviews. A list of all buildings and facilities the County owns and leases

was provided and the following information was collected to add to the list: 1)

address; 2) a facility contact person and phone number; 3) the year of

construction; 4) square footage; 5) survey information (Attachment I). Since the

original list was created, the County has added more facilities and the list has

been updated to reflect the change.

B. Survey Tools

In order to create a format for collecting the facility information that would

form the basis of the Transition Plan, survey tools were developed. In designing

the facility survey tool, the main goal was to understand how an individual with

a particular disability “navigates” through a facility. The facility survey tool is

divided into three broad categories:

1. Exterior Accessibility

Once a person arrives at a facility site, individuals with disabilities

should be able to approach a building and enter the building as freely as

everyone else. For instance, at least one accessible route must be

provided within the site from accessible parking spaces and accessible

passenger loading zones; public streets and sidewalks; and public

transportation stops to the accessible building or facility entrance they

serve.


ADA TRANSITION PLAN

2. Interior Accessibility

The interior accessible route connects the accessible entrance with the

program and services area. Typically, interior accessible routes are

made up of hallways, corridors, and interior rooms and spaces. The

accessible route is essential for people who have difficulty walking or

who use wheelchairs or other mobility aids to access the services and

programs areas. Additionally, people who are blind or have low vision

may walk along any route to access the programs and services area, such

as hallways, corridors, and service and programs spaces must be free of

objects that cannot be detected by a person who is blind or visually

impaired. Interior accessibility also includes restrooms, drinking

fountains, and other things such as accessible counter tops.

3. Program Accessibility

A public entity may not deny the benefits of its programs, activities, and

services to individuals with disabilities because its facilities are

inaccessible. A public entity’s services, programs, or activities, when

viewed in their entirety, must be readily accessible to and usable by

individuals with disabilities. This standard, known as “program

accessibility” applies to all existing facilities of a public entity. Public

entities, however, are not necessarily required to make each of their

existing facilities accessible. The County of El Paso will require, in

accordance with ADA and TAS, all new buildings and facilities to

comply with the 2010 ADA and TAS or the most currant code adopted.

The results of these surveys form the basis of this transition plan and form a strategy

for remediation of identified barriers. The survey tool is adaptable for each facility

in the County. (Attachment II).

Inspection surveys were also created for policy/procedures and communication

compliance. These surveys solicit information on how County agencies

communicate with the public, and how policies and procedures might adversely

affect the disabled community, or provide for their inclusion in County programs

and services as required under the Americans with Disabilities Act and Texas

Accessibility Standards. This portion of the review provides important context to

the detail of the program and facility assessment surveys.


ADA TRANSITION PLAN

Self-Evaluation/Data Collection

The development of an ADA Transition Plan requires the county to complete a number of

requirements. While the requirements are broadly defined to apply evenly across all public

entities, the resulting ADA Transition Plan, once completed, is a unique document of the

specific entity’s effort to achieve inclusion for its disabled community.

The general requirements of Title II of the Americans with Disabilities Act are as follows:

A. Establishment of Disability Services and Position of ADA

Coordinator

The El Paso County Commissioners entered into an agreement on May 26th,

2011. In this agreement it stated the County would designate one or more

employees as the County’s ADA Coordinator. Prior to this agreement no person

had been appointed to ADA responsibilities. The Director of Human Resources

and the Director of Public Works were designated as interim ADA Coordinators

by the El Paso County Commissioners.

The HR Director's role was dedicated to addressing any issues as they pertain

to applicants or employees of the County, including the initiation of a complaint

and grievance procedure and providing information to County employees. After

conducting extensive research, the HR Director submitted complaint and

grievance procedures for adoption by the County (Attachment VI).

The role of the Public Works Director was dedicated to ensuring all County

facilities are in compliance with the ADA and TAS standards. The Public

Works Director oversaw the improvements at Ascarate Park, which were a part

of the settlement agreement.

These duties were shared by both directors until a full time ADA Coordinator

was hired. The County posted the open position on the website. There was

funding for the position with more funding to be expected beginning October

1, 2011, for supplies and equipment.

An ADA Coordinator was hired and started November 28, 2011. The new ADA

Coordinator took over duties shared by Mr. Carrizal and Ms. Keller the HR

Director and the Public Works Director. The Human Resources Department is

involved with employment issues pertaining to ADA. The ADA Coordinator

has evaluated Ascarate Park and other facilities for ADA and TAS compliance.

The ADA Coordinator will continue this procedure with all County Parks and

facilities throughout the County.


ADA TRANSITION PLAN

The Human Resources Department has been directed to centralize the oversight

of the Transition Plan and see to the full implementation of this program county

wide. The Human Resources Department has assumed the management and

coordination of the County’s ADA compliance program for all departments

throughout the County. In the case of the Coliseum, the Human Resources

Department will provide limited coordination role, with technical assistance

provided to said agency on an as requested basis.

The Human Resources Department is responsible for tracking the County’s

compliance with the ADA and TAS. This department is also focused on

effective implementation of countywide initiatives for improving access for

those with disabilities.

The ADA Coordinator, along with the Human Resources Department, is

charged with the implementation of the Transition Plan. A more detailed

description of the ADA Coordinator is included as an attachment to this report.

(Attachment V)

B. Issue Notice of ADA Requirements

In accordance with Section 35.106 of the ADA, the County reviewed the

requirements of issuance of the ADA notice of compliance. El Paso County

issued a notice and is in keeping with the letter and spirit of the ADA legislation.

C. Grievance Procedures for County Services, Programs, and

Activities

Prior to the settlement agreement there was not a formal grievance procedure

for employees or residents of the County. When the Human Resource Director

was appointed interim ADA Coordinator the first task was creating grievance

procedures for the County.

The HR Director conducted extensive research and sought guidance from

various governmental agencies on grievance procedures. After researching and

with help from the County Attorneys’ Office the County has an effective

grievance procedure which adheres to both the letter and the intent of the law.

(Attachment VI)


ADA TRANSITION PLAN

Since the grievance procedures have been adopted they have not been changed.

The grievance procedures have proven to be effective in not only protecting the

County but also making the County more aware of ongoing issues due to age

of buildings. The County has been able to make changes to these facilities and

make them more compliant and accessible for people with disabilities. During

this next phase in the Transition Plan, the grievance forms will be updated. This

update will include the ability to submit them online.

D. Policies and Procedures Review

The goal of the ADA is to integrate people with disabilities into existing

programs instead of creating separate programs. An entity cannot require an

individual to participate in a separate program nor can it restrict an individual

from participating in general programs and activities. Individuals with

disabilities must be assured an equal opportunity to participate in the programs,

services, and activities offered by a public entity. Programs, services and

activities are required to be delivered in the most integrated and appropriate

setting possible.

Under the ADA, public entities are required to “make reasonable modifications

in policies, practices, or procedures when the modifications are necessary to

avoid discrimination on the basis of disability.” They are required to do so in

every situation, unless they can demonstrate “making the modifications would

fundamentally alter the nature of the service, program, or activity.”

The Reasonable Modifications Requirement is an important component to

programmatic access. It states every policy, procedure, and practice is

potentially subject to modification. This means the County will do whatever is

reasonable to ensure a person qualified to participate in a program or receive a

service receives as effective a service as any other qualified individual.

Section 35.130(b)(7) of the ADA requires a thorough review of both the

County’s formal written policies and the actual operating practices of each

program, service, or activity in relation to the general prohibitions against

discrimination contained in Title II of the ADA.

The County has reviewed policies in place and has implemented a new

complaint procedure. This procedure allows residents and employees submit

complaints and the reasonable accommodations they are requesting. This

allows the County to remedy the issue in an effective and timely manner.


ADA TRANSITION PLAN

E. ADA Communications Review

In accordance with Section 36.160(a) of Title II of the ADA, a public entity is

required to ensure effective communication with people with disabilities.

Equally effective communication means communication access which is

equally effective as that provided to people without disabilities. This includes

the requirement that a public entity provide auxiliary aids and service upon

request of a qualified person with a disability.

The effective communication requirement of the ADA is targeted largely at

barriers faced by people with sensory impairments; essentially, a requirement

to reasonably modify the way information is communicated. What distinguishes

the effective communication requirement from the general reasonable

modification requirement of the ADA is the specificity of the modifications it

mandates:

For people with vision impairments: written material must be

provided/accepted in large print, auditory or tactile (Brailled) form;

For people with hearing impairments: oral communication must be

provided/accepted in visual or amplified aural form:

For people with speech impairments: oral communication must either

be provided/accepted in written form, or the person must be allowed

sufficient time to communicate whatever must be communicated.

It is important to note the effective communication requirement applies to all

communications, and it requires programs to do whatever is necessary to ensure

their communications area is accessible to all people with disabilities, including

people with cognitive disabilities, developmental disabilities, and memory

disabilities, brain injuries which result in confusion, various psychiatric

disabilities and others.

Currently the County of El Paso Human Resources Department is in the process

of assessing and developing policies, procedures, and resources necessary to

ensure people with disabilities are not excluded, segregated, or restricted in any

way as a result of the communication barriers within the County.


ADA TRANSITION PLAN

F. Employment Policies and Practices Review

Title II of the Americans with Disabilities Act prohibits a public entity from

discriminating against qualified applicants or employees with a disability. It is

unlawful for a public entity to discriminate in any aspect of employment

including: application, testing, interviewing, hiring, evaluation, discipline,

compensation, promotion, termination, and benefits.

To ensure compliance with the provisions of Title II of the ADA, the County is

required to conduct a review of its employment policies and practices, including

the protocol for handling requests for reasonable accommodations and the

essential job functions associated with each job category.

Reasonable accommodation is a critical component of the ADA’s assurance of

nondiscrimination. Reasonable accommodation is any change in the work

environment or in the way tasks are usually done which results in equal

employment opportunity for an individual with a disability.

Essential job functions are those fundamental or critical job duties of the

employment position the individual with a disability holds or desires. The term

does not include the marginal tasks of the position. The ADA requires an

employer to focus on the essential functions of a job to determine whether a

person with a disability is qualified to do the job, with or without reasonable

accommodation.

The regulations list several reasons why a function could be considered

essential:

The position exists to perform the function

There are a limited number of other employees available to perform the

function, or among whom the function can be distributed.

A function is highly specialized, and the person in the position is hired

for special expertise or ability to perform it.

To identify job functions under the ADA, a job analysis should focus on the

purpose of the job and the importance of actual job functions in achieving this

purpose. Currently all of the County of El Paso’s essential job functions are

listed on the job description.

The County of El Paso’s Human Resources Department has developed

procedures to handle requests for reasonable accommodations for employment.

Reasonable accommodation forms have been developed for any person seeking

accommodations. Any person needing reasonable accommodation will work

with the Human Resources Department on determining the best way to provide

for their request.


ADA TRANSITION PLAN

Phase II: Recommendations and Prioritization

Data Analysis

During Phase I of the ADA Transition Plan, the Human Resources Department completed

reviews of the County’s policies and procedures, communication resources and all County

programs. Reviews to several facilities and parks County wide have also been completed.

Reviews of all remaining County facilities and parks will be completed in the same fashion

in the years to come. These activities generated reports and survey documents for each

facility review. During Phase II, a detailed analysis was conducted of the data collected

during Phase I of the facilities reviewed. This will be continued throughout the process as

more facilities, programs, parks, and policies and procedures are reviewed.

Recommendations for these facilities were developed to correct identified deficiencies in

each of the four major areas in the facility survey. In addition cost estimates for removing

barriers were generated by the appropriate County facility management agencies.

Policy and Procedures Survey and Recommendations

The County’s Human Resources Department will be conducting a survey to all departments

to find out if improvements are needed in areas such as reasonable modifications and their

obligations under Title II of the ADA. We know training will be needed in these areas and

others. The survey will clarify to what extent we need and who will need the training.

We do know training will be needed for our new policies put into place. Reasonable

modifications will be the area most needed. The Human Resources Department has been

working with requests from people and their supervisors since the policy has been

developed, and realizes a need for training in this specific area. As the County progresses

through the Transition Plan, the surveys will uncover more areas needing training. At that

time the Human Resources Department will be able to tailor a training program for those

needs.

Communications Survey and Recommendations

The County of El Paso Human Resources Department will conducted a survey on

communications used throughout the County Departments. The purpose of this survey is

to assess the County’s ability to provide communications to individuals with disabilities

that is effective as the communication provided to individuals who do not have disabilities.

This survey will be focused on communications with people with hearing disabilities.

Further surveys will focus on other types of communication such as large print documents

and Braille.


ADA TRANSITION PLAN

The Human Resources Department is aware of a few of these deficiencies the County

currently has. Braille, audiotape, and assisted listening devices are some examples. We still

need to conduct more surveys to find all deficiencies. The communications surveys will

make this clear so we can provide communication equipment and training in those areas.

A. Auxiliary Aids and Services

In order to be in compliance with Section 35.160(b)(1) of Title II of the ADA,

the County is required to provide specific communication access in the form of

auxiliary aids and services upon request of a qualified individual with a

disability.

When it comes to basic communications, accessibility often can be created on

the spot. For example, to explain written instructions to individuals who have

vision impairments, employees can simply read the instructions out loud. In

many basic transactions, such as paying bills or filing applications,

communications provided through such simple methods will be as effective as

the communications provided to other individuals in similar transactions.

However, in situations that involve extensive, complex, or very significant

communication, creating access may require the use of a communication device

or a person with expertise in a certain form of communication, such as

American Sign Language interpreter. These devices and experts are referred to

as “auxiliary aids and services,” and under the ADA, programs are required to

furnish them whenever their use will create equal access.

B. Sign Language Interpreter Services

When sign language interpretation is necessary for effective communication,

Section 35.104 of the ADA requires it be provided by a “qualified interpreter”.

Under the ADA, the term “qualified interpreter” is defined as an individual

who is “able to interpret effectively, accurately, and impartially, both

receptively and expressively, using any necessary specialized vocabulary”. In

order to satisfy this requirement, it is recommended that a pre-qualified library

of eligible Sign Language Interpreter Service providers be established for this

purpose.


ADA TRANSITION PLAN

The County will be installing Video Remote Interpretation Systems County

wide to communicate with people through sign language. This is an online sign

language interpreter. Instead of waiting hours or days to obtain a sign language

interpreter, one will be available immediately online, and available in different

languages other than American Sign Language. Extensive research on other

government agencies policies for Sign Language Interpreter is being conducted

by the Human Resources Department to find what will best suit our needs and

the needs of the County’s citizens. The Human Resources Department will then

draft a policy with the guidance of the County Attorney’s office to present to

the County Commission.

C. Telecommunications Access

Section 35.161 of Title II of the ADA requires that where communication by

telephone is a major function of a particular agency within the County, TTY”s

should be available.

Under the ADA, programs that communicate with the public by telephone are

required to also use an equally effective system for communicating with people

who have hearing or speech impairments. This applies to incoming as well as

outgoing calls, which means if a program has a practice of allowing members

of the public to use its phones to make outgoing calls; it must provide an equally

effective alternative to members of the public with hearing or speech

disabilities.

The most common device used to create telecommunications access is the

teletype machine (TTY), which is a device that allows a user to send typed

messages over standard telephone lines. There is also a new service through

which a caller can connect to a third party via a video screen and thus

communicate in sign language. Telecommunication equipment can be used to

talk to others via a sign language interpreter, who uses a conventional telephone

at the same time to communicate with the deaf person’s party.

The Sheriff’s department has installed telecommunication equipment to replace

the old TTY systems. This is newer technology and will be easier to maintain

training for the officers using the system. One of the problems identified with

the old TTY systems was the lack of training and maintenance training for the

officers in the use of the TTY system.

The old TTY’s will be retained for back up use in the case of a

telecommunication equipment failure. This system has become the example

for the County in other areas and departments that may need this type of

communication.


ADA TRANSITION PLAN

D. Inclusion of Braille Services in County Agencies

One of the auxiliary aids that must be provided upon request is material in

Braille. At this time the County does not have Braille literature readily available

and there is not a policy in place if asked for Braille material.

The communications survey will be able to tell us all the programs the County

has and what areas will need Braille readily available. Extensive research on

other government agencies policies for Braille will be conducted by the Human

Resources Department to find what will best suit our needs and the needs of the

County’s citizens. The Human Resources Department will then draft a policy

with the guidance of the County Attorney’s office to present to the County

Commission.

The proposed communications policies and procedures will bring necessary

consistency and clarity to the delivery of service for individuals with

disabilities. Additionally, the purchase of communication technology and

equipment will ensure minimum delays in removing communication barriers

and will ensure employees have what they need to provide the individual

services that is critical to programmatic and communication access.

Employment Recommendations

To ensure compliance with the provisions of Title II of the ADA, the County is required to

conduct a review of its employment policies and practices, including the protocol for

handling requests for reasonable accommodations and the essential job functions

associated with each job category. The process of providing reasonable accommodations

need to be done in a timely manner and without delay, it can result in a violation of the

ADA otherwise.

Priority System Development

The Department of Justice recommends a priority system be instituted to implement all

recommendations for barrier removal. The primary prioritization system, meaning criteria

by which recommendations are ordered, is at the discretion of the County. As part of Phase

II, recognizing the County has limited funds and personnel, all buildings and facilities

cannot be immediately surveyed for identifiable barriers and all buildings and facilities

cannot immediately be made fully accessible. The Human Resources Department

recommends the following primary criteria be used as the basis for prioritizing the building

and facilities to survey, and based on buildings and facilities surveyed, removal of

identified barriers:


ADA TRANSITION PLAN

Priority One:

Critical Nature of the Service Provided: Facilities providing essential service

related to health and safety and programs that are unique to a building, facility, or

park and cannot occur at another location.

Priority Two:

Level of Use by the Public: Facilities that receive a high level of public use.

Priority Three:

Geographic Distribution: by selecting a range of facilities that are distributed

throughout the County, the County can ensure maximum access for all residents.

As part of the prioritization process, the Human Resources Department has utilized

community outreach for feedback and opinions of the prioritization of the buildings and

facilities.

A secondary prioritization system – for program-based barrier removal actions – has been

put forward by the Department of Justice for use by all entities in their prioritization of

remedial actions. The Department of Justice criteria listed below are used to assist in the

determination of specific program-based barrier removal actions within a building or

facility, on a secondary basis to the primary criteria noted above. This is based on Title III

regulations for planning readily achievable barrier removal projects.

Priority 1: Accessible Entrance into Facility:

The highest priority is placed on those barrier removal items that provide

accessibility at the main entrance of a facility or improve a path of travel to the

portion of the facility where program activities take place (e.g. parking, walks,

ramps, stairs, doors, corridors, etc.)

Priority 2: Access to Goods and Services:

A second level priority is placed on those barrier removal items that improve or

enhance access to program use areas (e.g. transaction counters, conference rooms,

public offices, etc.).


ADA TRANSITION PLAN

Priority 3: Access to Restrooms:

A third level priority is placed on those barrier removal items that improve access

to the restrooms (e.g. doors, stalls, water closets, lavatories, etc.).

Priority 4: Any Other Measures Necessary:

A fourth level priority is placed on those barrier removal items that improve access

to amenities serving program areas (e.g. drinking fountains, telephones, site

furnishings, etc.).

Based on the data collected during Phase I, Phase II evaluations sought to prioritize

recommendations based on priority as noted above. Through our surveys, public outreach,

and grievances filed we have found most complaints are based on accessibility to

restrooms. Although we follow the priority recommendations from the Department of

Justice in most cases, we do allow ourselves room to adjust the County’s own priorities

depending on each case.

Operational, Non-Structural and Structural Recommendations

During Phase II recommendations will be generated as a result of the surveys from Phase

I. These recommendations are going to be broke down into the following three categories

for ease in the management of data. This will also make it easier to track the data and know

how many different kinds of changes the County has made and will need to be made. The

Human Resources Department will also be able to track the progress the County makes

towards compliance.

Operational

Modifications which require minimal or no cost. These may include moving

furniture, adjusting or clearing reception areas, moving offices, and similar changes

of this nature.

Non-Structural

Modifications requiring effort beyond simple operational changes, which do not

rise to the level of physical modifications of existing facilities. Examples include

door knobs, mirrors, and signs, grab bars, and other control and operating

mechanisms.


ADA TRANSITION PLAN

Structural

Modifications requiring changes to the physical construction of a facility, or work

of similar scope.

As more surveys are completed over the next several years of the parks and facilities we

will have a better idea of how many different changes in each category the County will be

implementing. This categorization will allow for a smooth dissemination of the

recommendations to the departments or individuals responsible for the implementation.

Website

The County’s website will provide information to the public regarding ADA and TAS. The

website also contains the grievance procedures and forms for anyone who wishes to file a

complaint alleging discrimination on the basis of a disability in the accessibility of services,

activities, programs, or benefits by El Paso County. The County’s website will also include

accessibility features for anyone with vision impairment.

As the County progresses through the phases of the Transition Plan, updates will be given

on the facilities and parks being reviewed and where these facilities and parks are, on

becoming barrier free. This is part of the public outreach, accountability, and transparency

the County is focused and committed on throughout the entire process.

Budget

Budget planning will be required of various departments depending on which facilities and

parks are surveyed for the year. The department will receive a report on their facility and

will need to generate a cost estimate for the needed barrier removal and improvements

required of that specific facility or park.

Community Involvement and Outreach

One of the key elements of the Transition Plan implementation is the participation of

people with disabilities. . The participants with disabilities can identify key issues that may

not be readily apparent to the County. Their perspective on the impact of the barriers to

program access is essential to the accuracy of our findings. Interested persons, including

individuals with disabilities or organizations representing individuals with disabilities will

have the opportunity to comment on the approach and order we take in choosing the

buildings and facilities the County will survey.

Special presentations on the ADA Transition Plan have been made to

representatives of interested agencies, such as Volar Center for Independent

Living.


ADA TRANSITION PLAN

Status reports of the ADA Transition Plan were presented to Desert ADAPT

and meetings set up to allow review and input of the Transition Plan.

Information about the County’s Transition Plan will be posted on the County’s

website which will allow for public input on future updates of the Transition

Plan.

Moving forward, and upon County Commission approval, The Human Resources

Department will develop additional plans to inform the community about the Transition

Plan, its processes and outcomes, and how the plan benefits the community and improve

accessibility.

The Human Resources Department will issue notices in both print, electronic media, and

accessible formats, advising the public of upcoming events, and coordinate logistics

associated with holding the presentations. A major goal of this process will be the ongoing

solicitation and acceptance of feedback, and the implementation of improvements to the

County’s approach to ADA compliance that may arise from these meetings.

Phase III: Adoption and Implementation

Upon approval and adoption of the updated ADA Transition Plan, the County will continue to be

on their way to being in compliance with the requirements of Title II of the Americans with

Disabilities Act. Beyond the legal requirements, El Paso County and the Court of County

Commissioners are demonstrating, through this Transition Plan, their commitment to inclusion of

all County Citizens in public programs and facilities, as well as a dedication to transparency in

government and to a compliance monitoring system, coupled with increased community outreach

and involvement, will ensure El Paso County will be a leader in the effort to comply with the

Americans with Disabilities Act and the Texas Accessibility Standards, and continue the County’s

commitment to inclusion.

Public Outreach

Public outreach, accountability, and transparency are all crucial to the success of the ADA

Transition Plan. The Human Resources Department made use of the County website by

posting grievance forms and procedures. In the future as the Transition Plan progresses,

the website will be used for many other things such as updates on facilities and parks in

the process of barrier removal.

Public presentations on the County’s progress thus far have been presented to citizens of

the community to help answer questions and receive feedback. These presentations will

continue throughout the process as necessary.


ADA TRANSITION PLAN

Training

Training and other internal communication is critical to the effectiveness of the program

accessibility approach. Appropriate training and communication will maximize the level

of ADA knowledge among all county employees, and help ensure violations do not occur

because of lack of knowledge of policies and procedures governing accessibility. Similarly,

training addressing sensitivity is essential in ensuring county employees are aware of

sensitive issues regarding individuals with disabilities.

New hire training has been developed to provide newly hired employees with information

on sensitivity and how to accommodate people with disabilities. This training has also been

extended to existing county employees. Specialized training was also given to all detention

officers. Training will be offered on all new ADA related policies are put in place.

It is very important front line personnel be trained because they set the tone for the agency’s

integration with the public, and they often have an enormous impact on access to services

for individuals with disabilities.

BUILDINGS REVIEWED

One of the major goals of the County and the Transition Plan, is ensuring all County facilities are

accessible through barrier removal. Several County buildings were constructed before the ADA

and TAS were signed and adopted by the Federal Government and the state of Texas respectively.

Each year the Human Resources Department chooses 5 buildings to review for compliance with

the ADA and TAS and come up with recommendations for barrier removal. The following

buildings have been evaluated for compliance. Reports for each building have been generated

noting what areas may not be in compliance with the ADA and TAS.

Liberty Hall (200 S. Kansas)

The Former Tax Office & Garage #1 (501 Overland)

County Court House (500 E. San Antonio)

Parking Garage #2 (201 S. Campbell)

Adult Probation (3160 Lee Trevino) (Now located at

Sheriff’s Office Sparks Annex (12899 Sparks Dr.)

Juvenile Probation Detention (6314 Delta Dr.)

MDR Building (800 E. Overland)


ADA TRANSITION PLAN

North East Annex (4641 Cohen)

North West Annex (435 Vinton Rd)

East Side Annex (2350 George Dieter)

Justice of the Peace #1 (424 Executive Center)

Sports Park Restrooms (1780 Zaragoza Rd.)

Sports Park Parking (1780 Zaragoza Rd.)

New Tax Office Ascarate Annex (301 Manny Martinez Sr. Dr.)

Socorro Road Bus Stops (Various Locations)

PARTIAL BUILDINGS REVIEWED

Ysletta Annex Building A-1 (9521 Socorro Rd.) (Tax Office/Financial Recovery)

Ysletta Annex Building B-2 (9521 Socorro Rd.) (Justice of the Peace #5)

BUILDINGS CORRECTED

The Former Tax Office (501 E. Overland) (New Human Resources Area)

Parking Garage #2 (201 S. Campbell)

PARTIAL BUILDINGS CORRECTED

North East Annex (4641 Cohen) (Tax Office)

MDR Building (800 E. Overland)

Juvenile Probation Detention (6314 Delta Dr.)


ADA TRANSITION PLAN

PARKS REVIEWED

Ensuring all County parks are accessible is also one of the major goals for the County of El Paso

and the Transition Plan. Several County parks were constructed before the ADA and TAS added

a chapter for recreational area accessibility. Each year the Human Resources Department chooses

2 parks to review for compliance with the ADA and TAS and come up with recommendations for

barrier removal. The following Parks have been evaluated for compliance. Reports for each Park

have been generated noting what areas may not be in compliance with the ADA and TAS.

Gallegos Park (7361 Bosque)

Agua Dulce Park (15371 Kentwood)

Ruben Estrella Park (14633 Greg Dr.)

San Elizario Plaza (1521 San Elizario Road)

Sparks Park (12899 Sparks Dr.)

Westway Park (1301 Zinn)

Alejandra Flores Park (13665 Socorro RD)

Risinger Park (301 Grace)

San Felipe Park (16501 Fabens)

El Paso County Sportspark (1780 N. Zaragoza Rd.)

Ted Richardson Park (13000 Alarcon)

PARKS CORRECTED

Agua Dulce Park (15371 Kentwood)

PARTIAL PARKS CORRECTED

Gallegos Park (7361 Bosque)

Ruben Estrella Park (14633 Greg Dr.)


ADA TRANSITION PLAN

Sparks Park (12899 Sparks Dr.)

Westway Park (1301 Zinn)

Ted Richardson Park (13000 Alarcon)

Ascarate Park (6900 Delta Dr.)

SUMMARY

The original Transition Plan was implemented in January of 2012 and updated in 2015. This is the

second update for the transition plan. Some goals of the Transition Plan have been accomplished

while other goals are continuing. As stated in this Transition Plan full ADA compliance will take

the County years to achieve.

To allow for a more advantageous use of limited resources a three phase approach is used: data

collection, analysis, and implementation. This will allow Transition Plan survey’s to be done and

successfully completed in a timely manner with the follow up reports. Implementation of the

findings will also be started in a timely manner.

While barrier removal, program updates, and communication updates are all very important to the

Transition plan, county employees must be knowledgeable in ADA compliance and sensitivity. It

is essential that training occurs throughout the employee’s career with the county. This training

has been integrated into required continuing education like other areas such as ethics training.

Managers and Supervisors will need training to address situations they are likely to encounter such

as employee related issues. Additionally architects and engineers may need to receive specialized

training regarding ADA and TAS standards.

The County will ensure the highest level of compliance with the requirements of the ADA and

TAS, through technology and integrating and tracking changes in facilities and their use;

inspections of new facilities; and modifications to existing facilities. Facilities being updated will

be tracked and updates will be given on the county’s website.

In approving this updated ADA Transition Plan, the County of El Paso Court of Commissioners

is continuing to emphasize its commitment to the program and service accessibility for all of its

citizens. Upon approval, implementation of the program, with its focused enhancements to

facilities and programs, inclusion of additional policy and communication enhancements, and

accent on community outreach and training will continue.


ADA TRANSITION PLAN

RECOMMENDATIONS

In order to achieve full compliance with the requirements of Title II of the Americans with

Disabilities Act and the Texas Accessibility Standards, the following is recommended:

The ADA Transition Plan update be adopted by the Court of County Commissioners.

The recommendations governing operational, non-structural, and structural

modifications continue to be implemented.

The recommended prioritization criteria for removal of identified barriers be re-

adopted.

The external County website for public use be developed to keep citizens informed

about the County’s progress with the implementations of the ADA Transition Plan and

facility and parks improvement.

The Transition Plan be updated every two years to include surveys and reports from

facilities and parks surveyed for the previous two years.

Continued training to all new County employee hires, current County employees,

specialized training for supervisors and managers, and specialized training for

architects and engineers.


ADA TRANSITION PLAN

ATTACHMENTS


ADA TRANSITION PLAN

Attachment I: Facility Inventory


ADA TRANSITION PLAN

1 EL PASO COUNTY COURT HOUSE

500 E. San Antonio Precinct:2 ADA Inspection: Y

El Paso, TX 79901

2 MDR BUILDING

800 E. Overland Precinct:2 ADA Inspection: Y

El Paso, TX 79901

3 PARKING GARAGE #1 (HR, Liberty Hall)


El Paso, TX 79901

4 PARKING GARAGE #2

201 S. Campbell Precinct:2 ADA Inspection: Y

El Paso, TX 79901

5 NORTHEAST ANNEX

4641 Cohen Precinct:4 ADA Inspection: Y

El Paso, TX 79924

6 MISSION VALLEY ANNEX

190 San Elizario Rd. Precinct:3 ADA Inspection: N

Clint, TX 79836

7 YSLETA ANNEX

9521 Socorro Rd. Precinct:3 ADA Inspection: P

El Paso, TX 79927

8 MEDICAL EXAMINER BUILDING

4505 Alberta Precinct:2 ADA Inspection: N

El Paso, TX 79905

9 JUSTICE OF THE PEACE 6, PLACE 2

14608 Greg Precinct:3 ADA Inspection: N

El Paso, TX 79938

10 WAREHOUSE (PURCHASING)

3209 Rosa Precinct:2 ADA Inspection: N

El Paso, TX 79905

11 WAREHOUSE (Purchasing & Elections)

163 N. Cebada Precinct:2 ADA Inspection: N

El Paso, TX 79905

12 ROAD AND BRIDGE FABENS

1331 N. Fabens Precinct:3 ADA Inspection: N

Fabens, TX 79838

13 ROAD AND BRIDGE (Old Library)

1329 N. Fabens Precinct:3 ADA Inspection: N

Fabens, TX 79838

14 ROADA AND BRIDGE CANUTILLO

191 Canutillo Ave. Precinct:4 ADA Inspection: N

Canutillo, TX 79835

15 ROAD AND BRIDGE MONTANA VISTA

14698 Van Lane Precinct:3 ADA Inspection: N


ADA TRANSITION PLAN

El Paso, TX 79938

16 ASCARATE PARK

6900 Delta Dr. Precinct:2 ADA Inspection: P

El Paso, TX 79915

17 ASCARATE PARK (Clubhouse, Golf Cart

Storage)

6900 Delta Dr. Precinct:2 ADA Inspection: P

El Paso, TX 79915

18 ASCARATE PARK PAVILLION

6900 Delta Dr. Precinct:2 ADA Inspection: Y

El Paso, TX 79915

19 COLISEUM

4100 E. Paisano Precinct:2 ADA Inspection: P

El Paso, TX 79905

20 EQUESTRIAN CENTER`

4100 E. Paisano Precinct:2 ADA Inspection: N

El Paso, TX 79905

21 COLISEUM STOCK EXHIBIT


El Paso, TX 79905

22 LIVESTOCK BUILDING


El Paso, TX 79905

23 LOS PORTALES MUSEUM

1585 San Elizario Rd. Precinct:3 ADA Inspection: N

San Elizario, TX 79849

24 FABENS COMMUNITY CENTER

151 N. First St. Precinct:3 ADA Inspection: N

Fabens, TX 79838

25 CANUTILLO COMMUNITY CENTER

7351 Bosque Precinct:4 ADA Inspection: N

Canutillo, TX 79835

26 AGUA DULCE COMMUNITY CENTER

15371 Kentwood Precinct:3 ADA Inspection: N

El Paso, TX 79928

27 MONTANA VISTA COMMUNITY

CENTER

14664 Greg Precinct:3 ADA Inspection N

El Paso, TX 79938

28 SAN ELIZARIO COMMUNITY

CENTER

12500 Socorro Rd. Precinct:3 ADA Inspection: N


29 JUVENILE PROBATION

DEPARTMENT


ADA TRANSITION PLAN

6314 Delta Dr. Precinct:2 ADA Inspection: Y

El Paso, TX 79905

30 MULTI COUNTY TASK FORCE

8037 Lockheed Precinct:1 ADA Inspection: N

El Paso, TX 79925

31 DOWNTOWN DETENTION FACILITY


El Paso, TX 79901

32 SHERIFF SUBSTATION AT SPARKS

12899 Sparks Dr. Precinct:3 ADA Inspection: Y

El Paso, TX 79928

33 SHERIFF HEADQUARTERS

3850 Justice Dr. Precinct:1 ADA Inspection: N

El Paso, TX 79938

34 JAIL ANNEX ACADEMY AND GYM

12501 Montana Precinct:1 ADA Inspection: N

El Paso, TX 79938

35 JAIL ANNEX FIRE ARM TRAINING

CENTER


El Paso, TX 79938

36 JAIL ANNEX HOUSING POD 1


El Paso, TX 79938



El Paso, TX 79938



El Paso, TX 79938


12501 Montana Precinct:1 ADA Inspection: Y

El Paso, TX 79938

40 JAIL ANNEX SHERIFF SUBSTATION


El Paso, TX 79938

41 JAIL ANNEX SUPPORT CENTER

12501 Montana Precinct:1 ADA Inspection: P

El Paso, TX 79938

42 ROAD AND BRIDGE ON SITE SEWER

14664 Greg Precinct:3 ADA Inspection: N

El Paso, TX 79938

43 LANDMARK PROPERTY

Rio Grand/Campbell Precinct:2 ADA Inspection: N

El Paso, TX 79901


ADA TRANSITION PLAN

44 RUBEN ESTRELLA-SOTO PARK

14590 Greg Precinct:3 ADA Inspection: Y

El Paso, TX 79938

45 GALLEGOS PARK

7361 Bosque Rd. Precinct:4 ADA Inspection: Y

Canutillo, TX 79835

46 AGUA DULCE PARK

15371 Kentwood Precinct:3 ADA Inspection: Y

El Paso, TX 79928

47 ALEJANDRA FLORES PARK

13665 Socorro Rd. Precinct:3 ADA Inspection: Y


48 RISINGER PARK

301 Grace Precinct:3 ADA Inspection: Y

Fabens, TX 79838

49 SAN FELIPE PARK

16501 Fabens Carlsbad Rd Precinct:3 ADA Inspection: Y

Fabens, TX 79838

50 TED RICHARDSON PARK

13000 Alarcon Precinct:3 ADA Inspection: Y


51 O’DONNELL/VETERANS PARK

602 NE 4th St. Precinct:3 ADA Inspection: Y

Fabens, TX 79838

52 SAN ELIZARIO PLAZA

1521 San Elzario Rd. Precinct:3 ADA Inspection: Y


53 WESTWAY PARK

1301 Zinn Precinct:4 ADA Inspection: Y

Canutillo, TX 79835

54 SPARKS PARK

12899 Sparks Dr. Precinct:3 ADA Inspection: Y

El Paso, TX 79928

55 ADULT PROBATION

7145 Industrial Precinct:2 ADA Inspection: N

El Paso, TX 79915

56 CAROLINA COMMUNITY CENTER

601 N. Carolina Precinct:3 ADA Inspection: N

El Paso, TX 79915

57 FRIENDLY COMMUNITY CENTER

2215 Murchison Precinct:2 ADA Inspection: N

El Paso, TX 79930

58 TAX OFFICE (FT. BLISS)

Bldg. 505, Ft. Bliss Precinct:2 ADA Inspection: N


ADA TRANSITION PLAN

505 Pershing Rd. El Paso, TX 79906

59 JUSTICE OF THE PEACE #1

424 Executive Center Precinct:2 ADA Inspection: Y

El Paso, TX 79902

60 JUSTICE OF THE PEACE #4

1219 Barranca Precinct:1 ADA Inspection: N

El Paso, TX 79935

61 HIDTA

4141 Pinnacle, Ste 120 Precinct:2 ADA Inspection: N

El Paso, TX 79902

62 EL PASO COUNTY TAX OFFICE

(Ascarate Annex)

301 Manny Martinez Dr. Precinct:2 ADA Inspection: Y

El Paso, TX 79905

63 ASCENCION CEMETARY

High Campus Rd. Precinct:3 ADA Inspection: N

El Paso, TX 79928

64 EAST SIDE ANNEX

2350 George Dieter Precinct:1 ADA Inspection: Y

El Paso, TX 79936

65 EPC SPORTS PARK

1780 Zaragoza Rd. Precinct:1 ADA Inspection: Y

El Paso, TX 79936

66 HORIZON HILLS PARK

12650 Mark Twain Ave. Precinct:3 ADA Inspection: Y

El Paso, TX 79928

67 NORTHWEST ANNEX

435 Vinton Rd. Precinct:4 ADA Inspection: Y

Vinton, TX 79821

68 TGIPOE BRIDGE

18500 Island Guadalupe Precinct:3 ADA Inspection: N

Tornillo TX, 79853

69 TGIPOE TOLL FACILITY

1398 Lower Island Precinct:3 ADA Inspection: Y

Tornillo TX, 79835

70 FAMILY YOUTH SERVICES CENTER

6400 Delta Precinct:2 ADA Inspection: Y

El Paso, TX 79905


ADA TRANSITION PLAN

Attachment II: Surveys


ADA TRANSITION PLAN

Priority 1 – Approach and Entrance Comments Reference

Parking Accessible parking spaces should be identified by size, access aisle, and signage.

Is there at least one route

from site arrival points

(parking, passenger

loading zones, public

sidewalks, and public

transportation stops) that

does not require the use

of stairs?

206.2.1

Are the minimum

number of accessible

parking spaces provided,

based on the total number

of available parking

spaces?

502

208.2

Are the accessible spaces

the ones closest to an

accessible entrance?

Note: If parking serves

multiple entrances,

accessible parking should

be dispersed.

208.3.1

Of the accessible spaces,

is at least one a van

accessible space?*

*For every 6 or fraction of 6 parking spaces

required by the table above, at least 1 should

be a van accessible space.

208.2.4

Is there an access aisle

serving the parking

spaces and adjoining an

accessible route? Two

parking spaces shall be

permitted to share a

common access aisle.

502.3

Are accessible car

parking spaces at least 96

inches wide and an

access aisle at least 60

inches wide.

502.2

502.3


ADA TRANSITION PLAN

Are van accessible

parking spaces at least

132 inches wide? Van

parking spaces are

permitted to be 96 inches

wide minimum where the

access aisle is 96 inches

wide minimum.

502.2

Exception

Is at least 98 inches of

vertical clearance

provided for the van

accessible space?

502.5

Is the access aisle marked

so as to discourage

parking in it?

502.3.3

Does the access aisle

overlap the vehicular

way?

502.3.4

Do angled van parking

spaces have access aisles

located on the passenger

side of the parking space?

502.3.4

Are all accessible parking

spaces, including access

aisles stable, firm and slip

resistant? Are the access

aisles the same level as

the parking spaces they

serve?

302.1

502.4


adjoin an accessible

route?

502.3

Are accessible spaces

identified with a sign that

includes the International

Symbol of Accessibility?

502.6


ADA TRANSITION PLAN

Is the bottom of the sign

at least 60 inches above

the ground? Are signs reading “van

accessible” at van

accessible spaces?

502.6

Are all parking spaces

and access aisles

designed so that cars and

vans, when parked,

cannot obstruct the

required clear width of

adjacent accessible

routes?

502.7

Exterior Accessible Route

Is the route stable, firm,

and slip-resistant?

302.1

Is there route of travel

that does not require the

use of stairs?

Is the route at least 36

inches wide?

403.5.1

Note: The accessible

route can narrow to 32

inches min. for a max. of

24 inches. These

narrower portions of the

route must be at least 48

inches from each other.

If the route is greater than

200 feet in length and less

than 60 inches wide, is

there a passing space no

less than 60 x 60 inches?

403.5.3

If there are grates or

openings on the route, are

the openings no larger

than ½ inches?

Is the long dimension

perpendicular to the

dominant direction of

travel?

302.3


ADA TRANSITION PLAN

Can all objects

protruding into the

circulation paths be

detected by a person with

a visual disability?

Objects with leading

edges more than 27

inches and not more than

80 inches above the

finish floor or ground

shall protrude 4 inches

maximum horizontally

into the circulation path.

307.2

Is the running slope of a

walking surface no

steeper than 1:20, i.e. for

every inch of height

change there are at least

20 inches of route run?

Note: If the running slope

is steeper than 1:20, treat

as a ramp and add

features such as edge

protection and handrails.

403.3

Is the cross slope no

steeper than 1:48?

403.3

Curb Ramps

If the accessible route

crosses a curb, is there a

curb ramp?

402.2

Is the running slope of the

curb ramp no steeper than

1:12, i.e. for every inch of

height change there are at

least 12 inches of curb

ramp run?

405.2

406.1


ADA TRANSITION PLAN

Is the cross slope of the

curb ramp, excluding

flares, no steeper than

1:48?

405.3

406.1

Is the curb ramp,

excluding flares, at least

36 inches wide?

405.5

406.1

At the top of the curb

ramp is there a level

landing (slope no steeper

than 1:48 in all

directions) that is at least

36 inches long and at

least as wide as the curb

ramp?

If there are curb ramp

flares, are the slopes of

the flares no steeper than



least 10 inches of flare

run?

406.3

406.4

If the landing at the top is

less than 36 inches long,

are there curb ramp

flares?

Are the slopes of the

flares no greater than

1:12?

406.4

Ramps If any portion of the accessible route is steeper than 1:20, it should be treated as a ramp.

If there is a ramp, is it at

least 36 inches wide?

Note: if there are

handrails, measure

between the handrails.

405.5

Is the surface stable, firm,

and slip resistant?

405.4


ADA TRANSITION PLAN

For each section of the

ramp, is the running slope

no greater than 1:12, i.e.

for every inch of height

change there are at least

12 inches of ramp run?

Note: Rises no greater

than 3 inches with a slope

no steeper than 1:8 and

rises no greater than 6

inches with a slope no

steeper than 1:10 are

permitted when such

slopes are necessary due

to limitations.

405.2

Is there a level landing

that is at least 60 inches

long and at least as wide

as the ramp:

At the top of the ramp?

At the bottom of the

ramp?

405.7.2

405.7.3


where the ramp changes

direction that is at least

60 x 60 inches?

405.7.4

Does the ramp rise no

more than 30 inches

between landings?

405.6

If the ramp has a rise

higher than 6 inches, are

there handrails on both

sides?

Note: Curb ramps are not

required to have

handrails.

405.8

Is the top of the handrail

gripping surface no less

than 34 inches and no

greater than 38 inches

above the surface?

505.4


ADA TRANSITION PLAN

Is the handrail gripping

surface continuous and

not obstructed along the

top or sides?

If there are obstructions,

is the bottom of the

gripping surface

obstructed no greater

than 20%?

505.3

505.6

If the handrail gripping

surface is circular, is it no

less than 1 ¼ inches and

no greater than 2 inches

in diameter?

505.7.1


surface is non-circular:

Is the perimeter no less


greater than 6 ¼ inches?

Is the cross section no


505.7.2

Is there at least 1 ½ min

clearance between the

handrail gripping surface

and adjacent surfaces?

505.5

Does the handrail:

Extend at least 12 inches

horizontally beyond the

top and bottom of the

ramp?

Return to a wall, guard,

or landing surface?

Note: if a 12 inch

extension would be a

hazard (in circulation

path) it is not required.

505.10.1


ADA TRANSITION PLAN

To prevent wheelchair

casters and crutch tips

from falling off:

Does the surface of the

ramp extend at least 12

inches beyond the inside

face of the handrail?

Or

Is there a curb or barrier

that prevents the passage

of a 4-inch diameter

sphere?

405.9.1

405.9.2

Entrance

Is the main entrance

accessible?

If the main entrance is not

accessible, is there an

alternative accessible

entrance?

Can the alternative

accessible entrance be

used independently and

during the same hours as

the main entrance?

Can the alternate

accessible entrance be

used independently?

Do all inaccessible

entrances have signs

indicating the location of

the nearest accessible

entrance?

216.6

If not all entrances are

accessible, is there a sign

at the accessible entrance

with the International


216.6

Is the clear opening width

of the accessible entrance

door at least 32 inches,

between the face of the

door and the stop, when

the door is open 90

degrees?

404.2.3


ADA TRANSITION PLAN

If there is a front

approach to the pull side

of the door, is there at

least 18 inches of

maneuvering clearance

beyond the latch side plus

at least 60 inches clear

depth?

Note: See 2010

Standards 404.2.4 for


requirements on the push

side of the door and side

approaches to the pull

side of the door

On both sides of the door,

is the ground or floor

surface of the


level (no steeper than

1:48)?

404.2.4

If the threshold is vertical

is it no more than ¼ high?

Or

No more than ½ inch

high with the top ¼ inch

beveled no steeper than

1:2, if the threshold was

installed on or after the

1991 ADA standards

went into effect

(1/26/93)?

Or

No more than ¾ inch

high with the top ½ inch

beveled no steeper than

1:2, if the threshold was

installed before the 1991

ADA Standards went

into effect (1/26/93)?

Note: The first ¼ inch of

the ½ or ¾ inch threshold

may be vertical; the rest

must be beveled.

303.2

404.2.5


ADA TRANSITION PLAN

Is the door equipped with

hardware that is operable

with one hand and does

not require tight

grasping, pinching, or

twisting of the wrist?

Door handle?

Lock (if provided)?

404.2.7

Are the operable parts of

the door hardware no less



above the floor or ground

surface?

404.2.7

If the door has a closer,

does it take at least 5

seconds to close from an

open position of 90

degrees to a position of

12 degrees from the

latch?

404.2.8

If there are two doors in a

series, e.g. vestibule, is

the distance between the

doors at least 48 inches

plus the width of the

doors when swinging

into the space?

404.2.6


ADA TRANSITION PLAN

Can doors be opened

without too much force?

5lbs for interior doors

and sliding or folding

doors.

404.2.9

If provided at the

building entrance, are

carpets or mats no higher

than ½ inch thick?

302.2

Are edges of carpets or

mats securely attached to

minimize tripping

hazards?

302.2


ADA TRANSITION PLAN

Priority 2 – Access to Goods and Services Comments Reference

Does the accessible entrance

provide direct access to the

main floor, lobby, and

elevator?

206.4

Interior Accessible Route Are all public spaces on at

least one accessible route?

206.2.4

Is the route stable, firm, and

slip-resistant?

302.1

402

Is the route at least 36 inches

wide?

Note: The accessible route

can narrow to 32 inches min.

for a max. of 24 inches. These

narrower portions of the route

must be at least 48 inches

from each other.

403.5.1

If the route is greater than 200

feet in length and less than 60

inches wide, is there a passing

space no less than 60 x 60

inches?

403.5.3

Is the running slope no steeper

than 1:20, i.e. for every inch

of height change there are at

least 20 inches of route run?

Note: If the running slope is

steeper than 1:20, treat as a

ramp and add features such as

edge protection and handrails.

403.3

Is the cross slope no steeper

than 1:48?

403.3


ADA TRANSITION PLAN

Do all objects on circulation

paths through public areas,

e.g. fire extinguishers,

drinking fountains, signs, etc.,

and protrude no more than 4

inches into the path?

Or

If an object protrudes more

than 4 inches, is the bottom

leading edge at 27 inches or

lower above the floor?

Or

Is the bottom leading edge at

80 inches or higher above the

floor?

307.2

307.4

Are there elevators or

platform lifts to all public

stories?

Note: Vertical access is not

required in new construction

or alterations if a facility is

less than three stories or has

less than 3,000 square feet per

story, unless the facility is a

shopping center, shopping

mall, professional office of a

health care provider,

transportation terminal, state

facility or local government

facility.


ADA TRANSITION PLAN

Ramps If there is a ramp, is it at least

36 inches wide?

Note: If there are handrails,

measure between the

handrails.

405.5

Is the surface stable, firm, and

slip resistant?

405.4

For each section of the ramp,

is the running slope no greater

than 1:12, i.e. for every inch

of height change there are at

least 12 inches of ramp run?

Note: Rises no greater than 3

inches with a slope no greater

than 1:8 and rises no greater

than 6 inches with a slope no

steeper than 1:10 are

permitted when due to space

limitations.

405.2

Is there a level landing that is

at least 60 inches long and at

least as wide as the ramp:


At the bottom of the ramp?

405.7.2

405.7.3

Is there a level landing where

the ramp changes direction

that is at least 60 x 60 inches?

405.7.4

If the ramp has a rise higher

than 6 inches are there

handrails on both sides?

405.8


gripping surface no less than

34 inches and no greater than

38 inches above the ramp

surface?

505.4


ADA TRANSITION PLAN


surface continuous and not

obstructed along the top or

sides?

If there are obstructions, is the

bottom of the gripping surface

obstructed no more than 20%

505.3

505.6


surface is circular, is it no less

than 1 ¼ inches and no greater

than 2 inches in diameter?

505.7.1



Is the perimeter no less than 4

inches and no greater than 6 ¼

inches?

Is the cross section no greater

than 2 ¼ inches in diameter?

505.7.2

Is the clearance between

handrail gripping surfaces and

adjacent surfaces at least 1 ½

inches min.

505.5


ADA TRANSITION PLAN

Does the handrail:


horizontally beyond the top

and bottom of the ramp?

Return to a wall, guard, or

landing surface?

Note: If a 12” extension

would be hazardous (in

circulation path), it is not

required.

505.10.1

To prevent wheelchair casters

and crutch tips from falling

off:

Does the surface of the ramp

extend at least 12 inches

beyond the inside face of the

handrail?

Or

Is there a curb or barrier that

prevents the passage of a 4 –

inch diameter sphere?

405.9.1

405.9.2

Elevators – Full Size and LULA (limited use, limited application) LULA elevators are often

used in alterations

If there is a full size or LULA

elevator, are the call buttons

no higher than 54 inches

above the floor?

407.2.1.1

Is the floor surface stable,

firm, and slip resistant?

302.1

Is the clearance between the

car platform sill and the edge

of the hoist way 1 ¼ inch or

less?

Does the car level to within ½

inch of the floor under rated

loading to zero loading

conditions?

407.4.3

407.4.4

Are there both visible and

audible door opening/closing

and floor indicators (one

tone= up, two tones = down)?


ADA TRANSITION PLAN

Are the visible signal fixtures

centered at 72 inches

minimum?

Are signal elements 21/2

inches minimum measured

along the vertical centerline of

the element?


elevator, does the sliding door

reopen automatically when

obstructed by an object or

person?

407.3.3

If there is a LULA elevator

with a swinging door:

Is the door power – operated?

Does the door remain open for

at least 20 seconds when

activated?

403.3.2

Is there a full size elevator:

Is the interior at least 54

inches deep by at least 36

inches wide with at least 16

sq. ft. of clear floor area?

Is the door opening width at

least 32 inches?

407.4.1

If there is a LULA elevator, is

the interior:

At least 51 inches deep by 51

inches wide with a door

opening width of at least 36

inches?

Or

At least 54 inches deep by at

least 36 inches wide with at

least 15 sq. ft. of clear floor

area and a door opening width

of at least 32 inches?

408.4.1

Exceptions 1

and 2

Is there a clear floor space at

the call controls? The clear

floor space needs to be 30 x

48 inches min?

407.2.1.3


ADA TRANSITION PLAN


elevator, are the in-car

controls:

No less than 15 inches and no

greater than 48 inches above

the floor?

Or

Up to 54 inches above the

floor for a parallel approach?

407.4.6.1

408.4.6

If there is a LULA elevator,

are the in-car controls

centered on a side wall?

408.4.6


elevator:

Are the car control buttons

designated with raised

characters?

Are the car control buttons

designated with Braille?

Are buttons ¾ inch minimum

in diameter, and arranged

with numbers in ascending

order, and read from left to

right?

407.4.7.1

703.2

407.4.6.2.1

407.4.6.2.2

Is the up designated call

button above the down

designated call button?

407.2.1.4

Are the emergency controls

grouped at the bottom of the

panel with the centerline 35

inches minimum above the

floor?

407.4.6.1

407.4.6.2

If there is a full size LULA

elevator, are there audible

signals which sound as the car

407.4.8


ADA TRANSITION PLAN

passes or is about to stop at a

floor?


elevator:

Is there a sign on both door

jambs at every floor

identifying the floor?

Is there tactile star on both

jambs at the main entry level?

Do text characters contrast

with their backgrounds?

Are text characters raised?

Is there Braille?

Is the sign mounted between

48 inches to the baseline of

the lowest character and 60

inches to the baseline of the

highest character above the

floor?*

Are there audible and visual

car position indicators located

above the car control panel or

above the door with

characters that are ½ inch high

minimum?

407.2.3

408.2.3

Platform Lifts If a lift is provided, can it be

used without assistance from

others?

410.1

Is the floor stable, firm, and

slip resistant?

Is there a change in level

greater than ¼ inch?

302

410.2


least 30 inches wide by at

least 48 inches long for a

person using a wheelchair to

approach and reach the

controls to use the lift?

410.5


ADA TRANSITION PLAN

Are the lift controls no less

than 15 inches and no greater

than 48 inches above the

floor?

410.5



least 48 inches long inside the

lift?

410.3

If there is an end door, is the

clear opening width at least 32

inches?

410.6

If there is a side door, is the

clear opening width at least 42

inches?

410.6

Is the clearance between the

platform sill and the edge of

the runway landing less than 1

inch max.?

410.4

Are the doors or gates low-

energy power?

Do they remain open for 20

seconds min.?

410.6

Stairways Interior and exterior stairs that are part of a means of egress.

Do all sets of stairs have

uniform riser heights and

uniform tread depths?

Risers need to be 4 inches

high min and 7 inches high

max.

Treads need to be 11 inches

deep min.

504.2

Do the treads have a non-slip

surface?

Are there changes in level on

the tread surface?

Note: Open risers are not

permitted.

504.3

504.4


ADA TRANSITION PLAN

Do stairs have continuous

rails on both sides?

504.6


gripping surface no less than


38 inches above the stair

nosings?

505.4




sides?

If there are obstructions, is the

bottom of the gripping surface

obstructed no more than 20%

505.3

505.6


surface is circular, is it no less

than 1 ¼ inches and no greater

than 2 inches in diameter?

505.7.1



Is the perimeter no less than 4

inches and no greater than 6 ¼

inches?

Is the cross section no greater

than 2 ¼ inches in diameter?

505.7.2

Is the clearance between

handrail gripping surfaces and

adjacent surfaces at least 1 ½

inches min.

505.5


ADA TRANSITION PLAN

Does the handrail:


horizontally beyond the top of

the stairs?

At the bottom of the stairs,

does the handrail extend at the

slope of the stair flight for a

horizontal distance at least

equal to one tread depth

beyond the last riser nosing?


landing surface?

Note: If a 12” extension

would be hazardous (in

circulation path), it is not

required.

505.10.2

505.10.3

Signs “Tactile characters” are read using touch, i.e. raised characters and Braille.

If there are signs designating

permanent rooms and spaces

not likely to change over time,

e.g. room numbers and letters,

room names, and exit signs:

Do text characters contrast



Is there Braille?

Is the sign mounted:

On the wall on the latch side

of the door?

Note: Signs are permitted on

the push side of doors with

closers and without hold-open

devices.

With clear floor space beyond

the arc of the door swing

between the closed position

and 45-degree open position,

at least 18 x 18 inches

216.2

703.5

703.2

703.3

703.4.2

703.4.1


ADA TRANSITION PLAN

centered on the tactile

characters?*

So the baseline of the lowest

character is at least 48 inches

above the floor and the

baseline of the highest

character is no more than 60

inches above the floor?*

Note: If the sign is at double

doors with one active leaf, the

sign should be on the inactive

leaf; if both leaves are active

the sign should be on the wall

to the right of the leaf.

If there are signs that provide

direction to or information

about interior spaces:

Do text character contrast


Is the sign mounted so that

characters are at least 40

inches above the floor?

Note: Raised characters and

Braille are not required.

703.5.1

703.5.6

Interior Doors – to classrooms, medical exam rooms, conference rooms, etc. Is the door opening width at

least 32 inches clear, between

the face of the door and the

stop, when the door is open 90

degrees?

404.2.3

If there is a front approach to

the pull side of the door, is

there at least 18 inches of


beyond the latch side plus at

least 60 inches clear depth?

Note: See 2010 standards

404.2.4 for maneuvering

clearance requirements on the

push side of the door and side

of the door.

On both sides of the door, is

the floor surface of the

404.2.4


ADA TRANSITION PLAN

maneuvering clearance level

(no steeper than 1:48)?

If the threshold is vertical is it

no more than ¼ inch high?

Or

No more than ½ inch high

with the top ¼ inch beveled

no steeper than 1:2.

Or

No more than ¾ inch high

with the top ½ inch beveled


Note: The first ¼ inch of the

½ inch or ¾ inch threshold

may be vertical; the rest must

be beveled.

404.2.5

303.2


hardware that is operable with

one hand and does not require

tight grasping, pinching, or


Door handle?

Lock (if provided)?

404.2.7

Are the operable parts of the

hardware no less than 34

inches and no greater than 48


404.2.7

Can the door be opened easily

(5 pounds maximum force)?

Note: You can use a pressure

gauge or fish scale to measure

force. If you do not have one

you will need to judge

whether the door is easy to

open.

404.2.9


ADA TRANSITION PLAN

If the door has a closer, does

it take at least 5 seconds to

close from an open position of

90 degrees to a position of 12

degrees from the latch?

404.2.8.1

Rooms and Spaces – stores, supermarkets, libraries, etc. Are aisles and pathways to

goods and services, and to one

of each type of sales service

counters, at least 36 inches

wide?

403.5.1

Are floor surfaces stable,

firm, and slip resistant?

302.1

If there is carpet:

Is it no higher than ½ inch?

Is it securely attached along

the edges?

302.2

Rooms and Spaces – Judicial Facilities If there are central or court-

floor holding cells separated

by sex and age, does at least

one of each type must comply

with TAS standards.

231.3.1

231.3.2

Turning Space shall be 60 by

60 inches minimum or a T-

shaped turning space 36

inches by 36 inches

minimum.

304.3.1

304.3.2

If the court room has benches,

do the benches have clear

floor space of 30 inches

minimum by 48 inches

minimum?

807.2.2

903.2

305.3


ADA TRANSITION PLAN

Are the benches at least 42

inches long minimum and 20

inches deep minimum and 24

inches deep maximum?

807.2.2

903.3

Do the benches have back

support? If so, is the back

support 42 inches long

minimum, extend from a

point 2 inches maximum

above the seat surface to a

point 18 inches minimum

above the seat surface? Does

the back support measure 2

1/2 inches maximum from the

rear edge of the seat measured

horizontally?

807.2.2

903.4

Is the bench seat surface

height 17 inches minimum

and 19 inches maximum

above the finish floor or

ground?

807.2.2

903.5

Is the surface of the seat slip

resistant and will not

accumulate water?

807.2.2

903.7

If beds are provided, is there

clear floor space of 30 inches

minimum by 48 inches

minimum provided on at least

one side of the bed? Is this

positioned for a parallel

approach to the side of the

bed?

807.2.3

305.3

Is there at least one water

closet, one lavatory, and one

bathtub or shower provided

that is accessible?

807.2.4

Are audible and visible

emergency alarm systems

provided for the occupant?

807.3.1


ADA TRANSITION PLAN

If telephones are provided

within cells, they shall have

volume controls that provide a

gain adjustable up to 20 dB

minimum. For incremental

volume control it must

provide at least one

intermediate step of 12 dB or

gain minimum. An automatic

reset shall be provided.

807.3.2

704.3

Rooms and Spaces – Judicial Facilities

If there are areas that are

raised or depressed and

accessed by ramps or platform

lifts with entry ramps is there

an unobstructed turning space

that is 60 inches by 60 inches

minimum?

808.2

Is there clear floor space 30

inches minimum by 48 inches

minimum in the defined area

of the jury box or witness

stand?

808.3

305.3

Are the judges benches,

clerk's stations, bailiffs'

stations, deputy clerks'

stations, court reports' stations

and litigants' and council

station accessible?

808.4

Is there a clear floor or ground

space of 30 inches minimum

by 48 inches minimum for a

forward approach to the work

stations?

808.3

902.2


ADA TRANSITION PLAN

Are the tops of the work

surfaces 28 inches minimum



ground?

808.4

306.3

Is there knee clearance under

work stations?

808.4

306.3

Is there toe clearance under

work stations?

808.4

306.2

Rooms and Spaces – Detention Facilities

Are at least 2 %, but no fewer

than one, of the total number

of cells in a facility provided

with mobility features? If

there are special holding and

housing cells at least one cell

serving each purpose must

have mobility features.

232.2.1

232.3

Turning Space shall be 60 by

60 inches minimum or a T-

shaped turning space 36

inches by 36 inches

minimum.

807.2.1

304.3.1

304.3.2


ADA TRANSITION PLAN

Controls – light switches, security and intercom systems, emergency/alarm boxes, etc. Is there clear floor space at



forward or parallel approach?

Are the operable parts no

higher than 48 inches above

the floor?*

305.3

308

309.3

Can the control be operated

with one hand and without



309.4

Seating: Assembly Areas – theaters, auditoriums, stadiums, theater style classrooms, etc. Are an adequate number of

wheelchair spaces provided?

221.2.1

Are wheelchair spaces

dispersed to allow location

choices and viewing angles

equivalent to other seating,

including specialty seating

areas that provide distinct

services and amenities?

221.2.3


ADA TRANSITION PLAN

Where people are expected to

remain seated, do people in

wheelchair spaces have a

clear line of sight over and

between the heads of others in

front of them?

802.1.1.2

802.2.1.1

If there is a single wheelchair

space, is it at least 36 inches

wide?

802.1.2

If there are two adjacent

wheelchair spaces, are they

each at least 33 inches wide?

802.1.2

If the wheelchair space can be

entered from the front or rear,

is it at least 48 inches deep?

802.1.3

If the wheelchair space can

only be entered from the side,

is it at least 60 inches deep?

802.1.3

Do wheelchair spaces adjoin,

but not overlap, accessible

routes?

802.1.4


ADA TRANSITION PLAN

Is there at least one

companion seat for each

wheelchair space?

221.3

Is the companion seat located

so the companion is shoulder

–to-shoulder with the person

in a wheelchair?

221.3

Is the companion seat

equivalent in size, quality,

comfort and amenities to

seating in the immediate area?

802.3.2

Seating: At dining surfaces (restaurants, cafeterias, bars, etc.) and non-employee work surfaces (libraries,

conference rooms, etc.) Are at least 5%, but no less

than one, of seating and

standing spaces accessible for

people who use wheelchairs?

226.1

Is there a route at least 36

inches wide to accessible

seating?

403.5.1

At the accessible space(s), is

the top of the accessible

surface no less than 28 inches

and no greater than 34 inches

above the floor?

Note: If for children, the top

should be no less than 26


inches above the floor.

902.3




forward approach?

305.3


ADA TRANSITION PLAN

Does it extend no less than 17


inches under the surface?

Is there knee space at least 27

inches high and at least 30

inches wide?

Note: If for children, the knee

space may be 24 inches high.

306.2

306.3

Seating: General – reception areas, waiting rooms, etc. Is there at least one space at



person in a wheelchair?

802.1.2

802.1.3

Benches – In locker rooms, dressing rooms, fitting rooms This section does not apply to any

other benches.

In locker rooms, dressing

rooms, and fitting rooms, is

there at least one room with a

bench?

222.1

803.4


ADA TRANSITION PLAN



least 48 inches long at the end

of the bench and parallel to

the short axis of the bench?

Is the bench seat at least 42

inches long and no less than


24 inches deep?

Does the bench have back

support or is it affixed to a

wall?

Is the top of the bench seat no

less than 17 inches and no


the floor?

903

Check-Out Aisles – supermarkets, large retail stores, etc. Is the aisle at least 36 inches

wide?

904.3.1

Is the counter surface of at

least one aisle no higher than

38 inches above the floor?

904.3.2

Is the top of the counter edge

protection no higher than 2

inches above the counter

surface?

904.3.2


ADA TRANSITION PLAN

If there is a check writing

surface, is the top no less than


34 inches above the floor?

904.3.3

If there is more than one

check-out aisle is there a sign

with the International Symbol

of Accessibility at the

accessible aisle?

216.11

Sales and Service Counters – banks, stores, dry cleaners, auto repair shops, fitness

clubs, etc. Is there a portion of at least

one of each type of counter

that is:

No higher than 36 inches

above the floor?

At least 36 inches long?

904.4.1

Does the accessible portion of

the counter extend the same

depth as the counter top?

904.4


ADA TRANSITION PLAN




forward or parallel approach?

904.4

For a parallel approach, is the

clear floor space positioned

with the 48 inches adjacent to

the accessible length of

counter?

904.4.1

For a forward approach:

Do no less than 17 and no

greater than 25 inches of the

clear floor space extend under

the accessible length of the

counter?

Is there at least 27 inches

clearance from the floor to the

bottom of the counter?

306.2.2

306.2.3

306.3.1


ADA TRANSITION PLAN

Food Service Lines – in cafeterias, salad bars, eat-in fast food establishments, etc. Does at least one of each type

of self-service shelf or

dispensing device for

tableware, dishware,

condiments, food and

beverages have a forward or

parallel approach?

904.5.1

If there is an unobstructed

parallel approach, is the shelf

or dispensing device no


the floor?

308.3.1

If there is a shallow

obstruction no deeper than 10

inches with a parallel

approach, is the shelf or

dispensing device no higher


floor?

308.3.1

If there is an obstruction no


greater than 24 inches deep

with a parallel approach, is the

shelf or dispensing device no


the floor?

308.3.2


ADA TRANSITION PLAN

If there is an unobstructed

forward approach, is the shelf

or dispensing device no


the floor?

308.2.1

IF there is an obstruction no

deeper than 20 inches with a

forward approach:

Does clear floor space extend

under the obstruction that is at

least the same depth as the

obstruction?

Is the shelf or dispensing

device no higher than 48


904.5.1

If the obstruction is no less

than 20 inches and no greater

than 25 inches deep with a

forward approach:

Does clear floor space extend

under the obstruction that is at

least the same depth as the

obstruction?

Is the shelf or dispensing

device no higher than 44


904.5.1

If there is a tray slide, is the

top no less than 28 inches and


above the floor?

904.5.2


ADA TRANSITION PLAN

Priority 3 - Restrooms Comments References

If toilet rooms are available to

the public, is at least one toilet

room accessible? (Either one

for each sex, or one unisex.)

Note: if toilet rooms are

chiefly for children, e.g., in

elementary schools and day

care centers, use the

children’s specifications in

Toilets – 604.1, 604.8, 604.9,

609.4, and Lavatories and

Sinks – 606.2.

Are there signs at inaccessible

toilet rooms that give

directions to accessible toilet

rooms? (See 2010 TAS –

216.8)

If not all toilet rooms are

accessible, is there a sign at

the accessible toilet room with

the International Symbol of

Accessibility?

216.8

Accessible Route Is there an accessible route to

the accessible toilet room?

206.2.4


ADA TRANSITION PLAN

Signs at Toilet Rooms Do text characters contrast



Is there Braille?

Is the sign mounted:

On the wall on the latch side

of the door?

Note: Signs are permitted on

the push side of doors with

closers and without hold-open

devices.

With clear floor space beyond

the arc of the door swing

between the closed position

and 45-degree open position,

at least 18 x 18 inches

centered on the tactile

characters?*

So the baseline of the lowest

character is at least 48 inches

above the floor and the

baseline of the highest

character is no more than 60


Note: if the

sign is at

double doors

with one

active leaf,

the sign

should be on

the inactive

leaf; if both

leaves are

active, the

sign should

be on the

wall to the

right of the

right leaf.

703.5

703.2

703.3

703.4.1

703.4.2

Entrance Is the door opening width at




degrees?

404.2.3


the pull side of the door is



beyond the latch side plus 60

inches clear depth?

Note: See 2010 Standards

404.2.4 for maneuvering

clearance requirements on the

push side of the door and side

approaches to the pull side of

the door.

404.2.4


ADA TRANSITION PLAN

On both sides of the door, is

the floor surface of the

maneuvering clearance level

(no steeper than 1:48)?

If the threshold is vertical is it

no more than ¼ inch high?

Or

No more than ½ inch high

with the top ¼ inch beveled


Or

No more than ¾ inch high

with the top ½ inch beveled


Note: The first ¼ inch of the

½ or ¾ inch threshold may be

vertical; the rest must be

beveled.

303.2

404.2.5


hardware that is operable with

one hand and does not require



Door handle?

Lock (if provided)?

404.2.7


door hardware mounted no



the floor?

404.2.7


ADA TRANSITION PLAN

Can the door be opened easily

(5 pounds maximum force)?

Note: You can use a pressure

gauge or fish scale to measure

force. If you do not have one

you will need to judge

whether the door is easy to

open.

404.2.9

If the door has a closer, does

it take at least 5 seconds to

close from an open position of

90 degrees to a position of 12

degrees from the latch?

404.2.8.1

If there are two doors in a

series, e.g. vestibule, is the

distance between the doors at

least 48 inches plus the width

of the doors when swinging

into the space?

404.2.6

If there is a privacy wall and

the door swings out, is there at

least 24 inches of


beyond the door latch side and

42 inches to the privacy wall?

404.2.4


ADA TRANSITION PLAN

If there is a privacy wall and

the door swings in, is there at

least 24 inches of


beyond the door latch side and

at least 48 inches to the

privacy wall if there is no door

closer or at least 54 inches if

there is a door closer?

404.2.4

In the Toilet Room Is there a clear path to at least

one of each type of fixture,

e.g. lavatory, hand dryer, etc.

that is at least 36 inches wide?

403.5.1

Is there clear floor space

available for a person in a

wheelchair to turn around, i.e.

a circle at least 60 inches in

diameter or a T-shaped space

within a 60-inch square?

6032.1

In a single user toilet room if

the door swings in and over a

clear floor space at a n

accessible fixture, is there a

clear floor space at least 30 x

48 inches beyond the swing of

the door?

603.2.3

Exception 2

If the mirror is over a lavatory

or countertop, is the bottom

edge of the reflecting surface


above the floor?

Or

If the mirror is not over the

lavatory or countertop, is the

bottom edge of the reflecting

surface no higher than 35


603.3

If there is a coat hook, is it no



the floor?*

603.4


ADA TRANSITION PLAN

Lavatories The 2010 standards refer to sinks in toilet rooms as lavatories.

Does at least one lavatory

have a clear floor space for a

forward approach at least 30

inches wide and 48 inches

long?

606.2

Do no less than 17 inches and

no greater than 25 inches of

the clear floor space extend

under the lavatory so that a

person using a wheelchair can

get close enough to reach the

faucet?

306.2

Is the front of the lavatory or

counter surface, whichever is

higher, no more than 34


606.3


clearance from the floor to the

bottom of the lavatory that

extends at least 8 inches under

the lavatory for knee

clearance?

306.3.3

Is there toe clearance at least

9 inches high?

Note: Space extending greater

than 6 inches beyond the

available toe clearance at 9

inches above the floor is not

considered to clearance.

306.3.3

Are pipes below the lavatory

insulated or otherwise

configured to protect against

contact?

606.5


ADA TRANSITION PLAN

Can the faucet be operated

without tight grasping,

pinching, or twisting of the

wrist?

Is the force required to

activate the faucet no greater

than 5 pounds?

606.4

Soap Dispensers and Hand Dryers Are the operable parts of the

soap dispenser within one of

the following reach ranges:

Above lavatories or counters

no less than 20 inches and no

greater than 25 inches deep:


above the floor?

Above lavatories less than 20

inches deep: no higher than 48


Not over an obstruction: no


the floor?

308.2

308.2.2


ADA TRANSITION PLAN


hand dryer or towel dispenser

within one of the following

reach ranges:

Above lavatories or counters

no less than 20 inches and no

greater than 25 inches deep:


above the floor?

Above lavatories less than 20

inches deep: no higher than 48

inches above the floor:

Not over an obstruction: no


the floor?

Can the operable parts of the

hand dryer or towel dispenser

be operated without tight




activate the hand dryer or

towel dispenser no greater

than 5 pounds?

308.2

309.4

Water Closets in Single-User Toilet Rooms and Compartments (Stalls)

Is the centerline of the water

closet no less than 16 inches


from the side wall or

partition?

604.2

Is clearance provided around

the water closet measuring at

least 60 inches from the side

wall and at least 56 inches

from the rear wall?*

604.3.1


ADA TRANSITION PLAN

Does the front partition and at

least one side partition

provide toe clearance of 9

inches minimum above the

finished floor and 6 inches

deep minimum beyond the

compartment-side face of the

partition?

604.8.1.4

Is the height of the water

closet no less than 17 inches


above the floor measured to

the top of the seat?

604.4

Do grab bars with a circular

cross section have an outside

diameter of 1 ¼ inch

minimum and 2 inches

maximum?

609.2.1

Do no circular grab bars have

a cross section dimension of 2

inches maximum and

perimeter dimension of 4

inches minimum and 4.8

inches maximum?

609.2.2

Are the grab bars securely

attached to the wall or

partition?

609.8

Is there a grab bar at least 42

inches long on the side wall?

Is it located no more than 12

inches from the rear wall?

Does it extend at least 54

inches from the rear wall?

Is it mounted no less than 33


inches above the floor to the

top of the gripping surface?


clearance between the grab

bar and protruding objects

above?*

604.5.1

609.3

609.4


ADA TRANSITION PLAN

Is there at least 1 ½ inches


bar and projecting objects

below?*

Is the space between the wall

and the grab bar 1 ½ inches?

Is there a grab bar at least 36

inches long on the rear wall?


inches from the centerline of

the water closet on one side

(side wall)?


inches on the other (open)

side?

Is it mounted no less than 33


inches above the floor to the

top of the gripping surface?

Are there at least 12 inches


bar and protruding objects

above?*

Are there at least 1 ½ inches


bar and projecting objects

below?*

Is the space between the wall

and grab bar 1 ½ inches?

604.5.2

609.3

609.4

Are the grab bars and any wall

and other surfaces adjacent to

the grab bars free of sharp or

abrasive elements, and with

rounded edges?

609.5

Do the grab bars rotate in their

fittings?

609.6

If the flush control is hand

operated, s the operable part

located no higher than 48


604.6


ADA TRANSITION PLAN

If the flush control is hand

operated, can it be operated





activate the flush control no

greater than 5 pounds?

605.4

Is the flush control on the

open side of the water closet?

604.6

Is the toilet paper dispenser

located no less than 7 inches


from the front of the water

closet to the centerline of the

dispenser?

604.7

Is the outlet of the dispenser:

Located no less than 15 inches


above the floor?

No located behind grab bars?

604.7

Does the dispenser allow

continuous paper flow?

604.7

If shelves are provided in the

stall:

Are they located 40 inches


maximum above the floor?

604.8.3


ADA TRANSITION PLAN

If coat hooks are provided:

Are they 15 inches minimum


above the floor?

Or

Placed 48 inches maximum

with a forward reach depth of

20 inches or 44 inches

maximum with a forward

reach depth of 25 inches

maximum?

Or


with a side reach depth of 10

inches maximum or 46 inches

maximum with a side reach

depth of 24 inches maximum?

308.2

604.8.3

Toilet Compartments (Stalls) Is the door opening width at




degrees?

604.8.1.2


the pull side of the door, is



beyond the latch side plus 60

inches clear depth?

Note: See 2010 Standards

604.8.1.2 Doors for


requirements on the push side

of the door and side

approaches to the pull side of

the door.

Is the door self-closing?

604.8.1.2


ADA TRANSITION PLAN

Are there door pulls on both

sides of the door that are

operable with one hand and

do not require tight grasping,


wrist?*

604.8.1.2

Is the lock operable with one

hand and without tight



309.4


door hardware mounted no



the floor?

404.2.7

Is the compartment at least 60

inches wide?

604.8.1.1

If the water closet is wall

hung, is the compartment at

least 56 inches deep?

604.8.1.1

If the water closet is floor

mounted, is the compartment

at least 59 inches deep?

604.8.1.1


ADA TRANSITION PLAN

If the door swings in, is the

minimum required

compartment area provided

beyond the swing of the door

(60 inches x 56 inches if water

closet is wall hung or 59

inches if water closet is floor

mounted)?

604.8.1.1

Urinals Is the rim of the urinal 17

inches maximum above the

finish floor? Is the urinal 13 ½

inches deep minimum

measured from the outer face

of the urinal rim to the back of

the fixture?

605.2

Is there a clear floor space of

30 inches x 48 inches

minimum?

605.3

Flush controls can be manual

or automatic, if they are

manual, are they:

Operable with one hand and

don’t require tight grasping,


wrist?

Are they placed 15 inches


maximum above the floor?

Or


with a forward reach depth of

20 inches or 44 inches

maximum with a forward


maximum?

308.2.1

308.2.2

308.3.1

308.3.2

309.3

309.4

605.4


ADA TRANSITION PLAN

Or


with a side reach depth of 10

inches maximum or 46

inches maximum with a side


maximum?


ADA TRANSITION PLAN

Priority 4 – Additional Access Comments References

Drinking Fountains Does at least one drinking

fountain have a clear floor

space at least 30 inches wide

x at least 48 inches long

centered in front of it for a

forward approach?*

602.2

If there is a forward

approach, do no less than 17


inches of the clear floor

space extend under the

drinking fountain?

Note: If the drinking

fountain is primarily for

children’s use and the spout

is no more than 30 inches

above the floor and no more

than 3 ½ inches from the

edge of the unit, a parallel

approach is permitted.

If the drinking fountain is no

deeper than 20 inches, are

the operable parts no higher


floor?

308.2.2

If the drinking fountain is no


greater than 25 inches deep,

are the operable parts no


the floor?

308.2.2

Can the control be operated




309.4


ADA TRANSITION PLAN


activate the control no more

than 5 pounds?

Is the spout outlet no higher


floor?

602.4

Is the spout:

At least 15 inches from the

rear of the drinking fountain?

No more than 5 inches from

the front of the drinking

fountain?

602.5

If there is more than one

drinking fountain, is there at

least one for standing

persons?

Is the spout outlet no lower

than 38 inches and no higher


floor?

211.2

602.7

If the leading (bottom) edge

of the fountain is higher than

27 inches above the floor,

does the front of the fountain

protrude no more than 4

inches into the circulation

path?

307.2


ADA TRANSITION PLAN

Public Telephones Does at least one telephone

have a clear floor space at

least 30 inches wide x at least

48 inches long for a parallel

or forward approach?

704.2.1

Is the highest operable part

of the telephone no higher


floor?

704.2.2

If the leading (bottom) edge

of the telephone is higher


floor, does the front of the

telephone protrude no more

than 4 inches into the

circulation path?

307.2

Does at least on telephone

have a volume control?

704.3

Is the volume control

identified by a pictogram of

a telephone handset with

radiating sound waves?

703.7.2.3


ADA TRANSITION PLAN

Does at least one telephone

have a TTY?

Note: TTY’s are devices that

employ interactive text-

based communication

through the transmission of

coded signals across the

telephone network. They are

mainly used by people who

are deaf and/or cannot speak.

217.4.1

Is the touch surface of the

TTY keypad at least 34


Note: if a seat is provided,

the TTY is not required to be

34 inches minimum above

the floor.

704.4.1

Is the TTY identified by the

International Symbol of

TTY?

703.7.2.2

Do signs that provide

direction to public

telephones also provide

direction to the TTY?

216.9.2

Do telephones that do not

have a TTY provide

direction to the TTY?

216.9.2

Fire Alarm Systems If there are fire alarm

systems, do they have both

flashing lights and audible

signals?

702.1


ADA TRANSITION PLAN

Play Areas Comments Reference

Play Areas (2010 Standards – 206, 240, & 1008) Note: Play areas for children under age 2 and play areas

in family child care facilities where the proprietor resides do not have to comply.

Is there an accessible route

to the entrance of the play

area?

If there are separate play

areas within a site for

specific age groups, is there

an accessible route to each

play area?


within the play area

connecting ground level

play components that are

on an accessible route

including the entry and exit

points of those

components?

Priority 1: Approach and Entrance

Parking Accessible parking spaces should be identified by size, access aisle, and signage.

Is there at least one route

from site arrival points

(parking, passenger loading

zones, public sidewalks,

and public transportation

stops) that does not require

the use of stairs?

206.2.1

Are the minimum number

of accessible parking

spaces provided, based on

the total number of

available parking spaces?

502

208.2

Are the accessible spaces

the ones closest to an

accessible entrance?

Note: If parking serves

multiple entrances,

accessible parking should

be dispersed.

208.3.1

Of the accessible spaces, is

at least one a van accessible

space?*

*For every 6 or fraction of 6 parking spaces

required by the table above, at least 1 should

be a van accessible space.

208.2.4


ADA TRANSITION PLAN

Is there an access aisle

serving the parking spaces

and adjoining an accessible

route? Two parking spaces

shall be permitted to share

a common access aisle.

502.3

Are accessible car parking

spaces at least 96 inches

wide and an access aisle at

least 60 inches wide.

502.2

502.3

Are van accessible parking

spaces at least 132 inches

wide? Van parking spaces

are permitted to be 96

inches wide minimum

where the access aisle is 96

inches wide minimum.

502.2

Exception

Is at least 98 inches of

vertical clearance provided

for the van accessible

space?

502.5

Is the access aisle marked

so as to discourage parking

in it?

502.3.3


overlap the vehicular way?

502.3.4

Do angled van parking

spaces have access aisles

located on the passenger

side of the parking space?

502.3.4

Are all accessible parking

spaces, including access

aisles stable, firm and slip

resistant? Are the access

aisles the same level as the

parking spaces they serve?

302.1

502.4


ADA TRANSITION PLAN

Does the access aisle adjoin

an accessible route?

502.3

Are accessible spaces

identified with a sign that

includes the International


Is the bottom of the sign at

least 60 inches above the

ground?

502.6

Are signs reading “van

accessible” at van

accessible spaces?

502.6

Are all parking spaces and

access aisles designed so

that cars and vans, when

parked, cannot obstruct the

required clear width of

adjacent accessible routes?

502.7

Exterior Accessible Route Is the route stable, firm, and

slip-resistant?

302.1

Is there route of travel that

does not require the use of

stairs?


inches wide?

403.5.1


can narrow to 32 inches

min. for a max. of 24

inches. These narrower

portions of the route must

be at least 48 inches from

each other.






403.5.3


ADA TRANSITION PLAN



the openings no larger than

½ inches?




travel?

302.3

Can all objects protruding

into the circulation paths be

detected by a person with a

visual disability?

Objects with leading edges

more than 27 inches and

not more than 80 inches


ground shall protrude 4

inches maximum

horizontally into the

circulation path.

307.2


walking surface no steeper

than 1:20, i.e. for every

inch of height change there

are at least 20 inches of

route run?



ramp and add features such

as edge protection and

handrails.

403.3

Is the cross slope no steeper

than 1:48?

403.3

Curb Ramps If the accessible route


curb ramp?

402.2


ADA TRANSITION PLAN






ramp run?

405.2

406.1




1:48?

405.3

406.1

Is the curb ramp, excluding

flares, at least 36 inches

wide?

405.5

406.1

At the top of the curb ramp

is there a level landing

(slope no steeper than 1:48

in all directions) that is at

least 36 inches long and at


ramp?


flares, are the slopes of the

flares no steeper than 1:10,

i.e. for every inch of height

change there are at least 10

inches of flare run?

406.3

406.4


less than 36 inches long, are

there curb ramp flares?

Are the slopes of the flares

no greater than 1:12?

406.4




Note: if there are handrails,

measure between the

handrails.

405.5


and slip resistant?

405.4


ADA TRANSITION PLAN



no greater than 1:12, i.e. for

every inch of height change

there are at least 12 inches

of ramp run?

Note: Rises no greater than

3 inches with a slope no

steeper than 1:8 and rises


with a slope no steeper than

1:10 are permitted when

such slopes are necessary

due to limitations.

405.2

Is there a level landing that

is at least 60 inches long

and at least as wide as the

ramp:



405.7.2

405.7.3



direction that is at least 60

x 60 inches?

405.7.4

Does the ramp rise no more

than 30 inches between

landings?

405.6


than 6 inches, are there



required to have handrails.

405.8





above the surface?

505.4




sides?

505.3

505.6


ADA TRANSITION PLAN

If there are obstructions, is

the bottom of the gripping

surface obstructed no

greater than 20%?



less than 1 ¼ inches and no

greater than 2 inches in

diameter?

505.7.1



Is the perimeter no less than


6 ¼ inches?



505.7.2





505.5

Does the handrail:





landing surface?

Note: if a 12 inch extension

would be a hazard (in

circulation path) it is not

required.

505.10.1


ADA TRANSITION PLAN


casters and crutch tips from

falling off:





Or


that prevents the passage of

a 4-inch diameter sphere?

405.9.1

405.9.2

Play Areas Ground Level Play

Components


to at least one of each type

of ground level play

component?

Notes:

1. A play component is an

element designed to

generate play, socialization

and learning. In the 2010

Standards ramps, transfer

systems, steps, decks, and

roofs are not considered

play components.

2. Ground level play

components are

components that can be

approached and exited at

ground level. Examples

include rockers, swings,

diggers, and stand-alone

slides. When distinguishing

between types of

components consider the

experience provided.

Examples include rocking,

swinging, climbing,

digging, spinning, and

sliding.


ADA TRANSITION PLAN

If there are elevated play

components, is there an

accessible route to at least

the following number and

type of ground level play

components? See chart

below.

Notes:

1. The intent is to provide a

variety of experiences for

children who want to

remain in their wheelchair

or with another mobility

device and who choose not

to transfer to elevated

components.

2. If a play area includes

two or more composite

structures for the same age

group, use the total number

of elevated components to

determine the additional

number and types of

ground level play

components to provide on

an accessible route.

3. If ramps provide access

to at least 50 percent of the

elevated components and

the ramped route goes to at

least three different

elevated play types, the

ground level components in

the chart are not required.

4. The number of ground

level components

determined by “one of each

type” can fulfill the

minimum ground level

requirements in the table.


ADA TRANSITION PLAN

If two or more ground level

play components are on an

accessible route are they

dispersed throughout the

play area and integrated

with other play

components?

If there is a soft contained

play structure with three or

fewer entry point, is there

an accessible route to at

least one entry point?

If there are four or more

entry points, are there

accessible routes to at least

two entry points?

Notes:

1. A soft contained play

area is a play structure

made of one or more

components on which a

person enters a fully

enclosed play environment

that uses pliable materials

such as plastic, soft

padding, and fabric.

Accessible Route

Connecting Ground Level

Play Components

Note: If there is a water

play component and the

accessible route is

submerged, it is not

required to be slip resistant,

the running slope may be

steeper than 1:12 and the

cross slope may be steeper

than 1:48.

Is the vertical clearance of

the accessible route at least

80 inches above the ground

surface?

Note: Objects below 80

inches may not protrude

into the accessible route.

If the play area is less than

1000 square feet:


inches wide?


ADA TRANSITION PLAN

If the route exceeds 30 feet

in length is a wheelchair

turning space provided, i.e.

a circle at least 60 inches in

diameter or a T-shaped

space within a 60-inch

square?

If the play area is 1000

square feet or greater is the

route at least:

60 inches wide

Or

36 inches wide for a

distance no greater than 60

inches if reduced segments

at least 60 wide and at least

60 inches long?

Note: This permits

flexibility around site

features such as trees and

equipment.

Is the route no steeper than



least 16 inches of run?

If the route is steeper than

1:20 and the rise for a ramp

run is higher than 6 inches

are there handrails on both

sides of the ramp run?

Notes:

1. Handrail extensions are

not required.

2. Handrails are not

required on ramps within

ground level use zones. The

use zone is the area beneath

and adjacent to a play

structure upon which a user

would land when falling

from or exiting a play

structure.





above the ramp surface?


ADA TRANSITION PLAN


surface: Circular with an

outside diameter of at least

.95 inch and no more than

1.55 inches?

Or

Non-circular providing an

equivalent gripping

surface?

Elevated Play Components


to entry and exit points of at

least 50 percent of elevated

components?

Note: An elevated play

component is a component

approached above or below

grade that is part of a

structure of two or more

play components providing

more than one play activity.

If there are 20 or more

elevated play components

are at least 25% connected

by ramps?

Are the other 25% that are

required to be on an

accessible route connected

by either ramps or transfer

systems?

If there are fewer than 20

elevated play components

are at least 50% connected

by either ramps or transfer

systems.

Note: Ramps are preferred

but are not required.

Elevated Play Components

Accessible Route

Use the checklist for

Priority 1: Approach &

Entrance and the following

exceptions and

requirements.

Is the route stable, firm, and

slip-resistant?

302.1

Is there route of travel that

does not require the use of

stairs?


ADA TRANSITION PLAN


inches wide?

403.5.1


can narrow to 32 inches

min. for a max. of 24

inches. These narrower

portions of the route must

be at least 48 inches from

each other.






403.5.3



the openings no larger than

½ inches?




travel?

302.3

Can all objects protruding

into the circulation paths be

detected by a person with a

visual disability?

Objects with leading edges

more than 27 inches and

not more than 80 inches


ground shall protrude 4

inches maximum

horizontally into the

circulation path.

307.2


ADA TRANSITION PLAN


walking surface no steeper

than 1:20, i.e. for every

inch of height change there

are at least 20 inches of

route run?



ramp and add features such

as edge protection and

handrails.

403.3

Is the cross slope no

steeper than 1:48?

403.3

Curb Ramps If the accessible route


curb ramp?

402.2






ramp run?

405.2

406.1




1:48?

405.3

406.1

Is the curb ramp, excluding

flares, at least 36 inches

wide?

405.5

406.1


ADA TRANSITION PLAN

At the top of the curb ramp

is there a level landing

(slope no steeper than 1:48

in all directions) that is at



ramp?


flares, are the slopes of the

flares no steeper than 1:10,

i.e. for every inch of height

change there are at least 10

inches of flare run?

406.3

406.4


less than 36 inches long, are

there curb ramp flares?

Are the slopes of the flares

no greater than 1:12?

406.4




Note: if there are handrails,

measure between the

handrails.

405.5


and slip resistant?

405.4



no greater than 1:12, i.e. for

every inch of height change

there are at least 12 inches

of ramp run?

Note: Rises no greater than

3 inches with a slope no

steeper than 1:8 and rises


with a slope no steeper than

1:10 are permitted when

such slopes are necessary

due to limitations.

405.2


ADA TRANSITION PLAN

Is there a level landing that

is at least 60 inches long

and at least as wide as the

ramp:



405.7.2

405.7.3



direction that is at least 60

x 60 inches?

405.7.4

Does the ramp rise no more

than 30 inches between

landings?

405.6


than 6 inches, are there



required to have handrails.

405.8





above the surface?

505.4




sides?

If there are obstructions, is

the bottom of the gripping

surface obstructed no

greater than 20%?

505.3

505.6



less than 1 ¼ inches and no

greater than 2 inches in

diameter?

505.7.1


ADA TRANSITION PLAN



Is the perimeter no less than


6 ¼ inches?



505.7.2





505.5

Does the handrail:





landing surface?

Note: if a 12 inch extension

would be a hazard (in

circulation path) it is not

required.

505.10.1


casters and crutch tips from

falling off:





Or


that prevents the passage of

a 4-inch diameter sphere?

405.9.1

405.9.2


ADA TRANSITION PLAN

Is the accessible route

connecting elevated play

components:

At least 36 inches wide?

Or

At least 32 inches wide for

a distance no greater than

24 inches if the reduced

width segments are

separated by segments at



Or

If part of a transfer system,

at least 24 inches wide.

If there is a ramp are there


Note: Handrail extensions

are not required.





above the ramp surface?


surface is:

Circular, is the outside

diameter no less than .94

inch and no greater than

1.55 inch?

Non-circular, is it

equivalent to a circular

gripping surface with a

diameter no less than .94

inch and no greater than

1.55 inch?

Is the rise for any ramp run

connecting elevated play

components no greater than

12 inches?

If a transfer system is

provided is the transfer

system at least 24 inches

wide?

Is the top of the transfer

platform no less than 11

inches and no greater than

18 inches from the ground?

Is the transfer platform at

least 14 inches deep by at



ADA TRANSITION PLAN

Is there a clear transfer

space at least 30 inches

wide by at least 48 inches

long adjacent to the

platform, with the longer

dimension centered on and

parallel to the 24 inch

minimum long side of the

platform?

Is the side transfer platform

adjacent to the clear space

unobstructed?

If movement is intended

from transfer platforms to

levels with elevated play

components that are

required to be on an

accessible route, are

transfer steps provided?

Are transfer steps:

At least 14 inches deep?

At least 24 inches wide?

No higher than 8 inches?

Is there at least one means

of support for transferring:

On and off the platform?

Up and down the transfer

steps?

Note: Examples of supports

include a rope loop, a loop

type handle, a slot in the

edge of a flat horizontal or

vertical member, poles or

bars, or D rings on the

corner posts.

Play Components

Is there at least one clear

space for a person in a

wheelchair to turn around,

i.e. a circle at least 60

inches in diameter or a T-

shaped space within a 60-

inch square, at:

Ground level play

components on an

accessible route?


ADA TRANSITION PLAN

Elevated play components

connected by ramps?

Note: The turning space is

not required at elevated

play components

connected only by transfer

system.

If there are swings, is there

clear space for a person in a

wheelchair to turn around,

i.e. a circle at least 60

inches in diameter or a T-

shaped space within a 60-

inch square, immediately

adjacent to at least one

swing?

Is there a clear ground/floor

space at least 30 inches

wide and 48 inches long at:

Each ground level play

component required to be

on an accessible route?

Each elevated play

component required to be

on an accessible route that

is connected by ramps?

Notes:

1. The clear ground space is

not required at elevated

play components

connected only by transfer

system.

2. Clear ground spaces 30

inches minimum by 48

inches minimum, 60 inch

minimum turning spaces

and accessible routes may

overlap.

If there is a play table for

children older than 5 years:

Are tops of rims, curbs, or

other obstructions no


above the ground?

Is there clear ground space

at least 30 inches wide by at


forward approach?


ADA TRANSITION PLAN

Is there clear knee space

underneath:

At least 17 inches high?


inches deep?

Is it at least 30 inches wide?

If there is a play table for

children 5 years or

younger:

Does it provide knee space

as noted above?

Or

Is there clear ground space

at least 30 inches wide by at


parallel approach?

If a play component on an

accessible route requires

transfer to entry points or

seats:

Is the entry point or seat no


greater than 24 inches from

the clear floor/ground

space?

Is there at least one means

of transfer support?

Note:

Examples of supports

include a rope loop, a loop

type handle, a slot in the

edge of a flat horizontal or

vertical member, poles or

bars, or D rings on the

corner posts.


ADA TRANSITION PLAN

Ground Surfaces

Do ground surfaces inside

the play area (on accessible

routes, clear ground spaces,

and turning spaces) comply

with ASTM F 1951-99

Standard Specification for

Determination of

Accessibility of Surface

Systems Under and Around

Playground Equipment?

Notes:

1. ASTM is the American

Society for Testing and

Materials.

2. A portable device – the

Rotational Penetrometer –

measures surface firmness

and stability.

Do the ground surfaces

within use zones (the

ground level area beneath

and immediately adjacent

to a play structure or play

equipment that is

designated for unrestricted

circulation around the play

equipment and where it is

predicted that a user would

land when falling from or

exiting the play equipment)

comply with ASTM F 1292-

04 Standard Specification

for Impact Attenuation of

Surfacing Materials Within

the Use Zone of

Playground Equipment?


ADA TRANSITION PLAN

Attachment III: Policies and Practices Survey


ADA TRANSITION PLAN

AMERICANS WITH DISABILITIES ACT

POLICIES AND PRACTICES SURVEY

Human Resource Department

Public entities are required to review both written policies and the actual operating practices used

in programs and activities, to ensure that people with disabilities are not discriminated against.

Title II contains broad prohibitions against discrimination, addressing issues of equal opportunity,

integration, eligibility, methods of administration, relationships with contractors, location of

facilities, licensing, and others.

In order to facilitate the gathering of information and the communication of these complex legal

requirements to program staff, this worksheet groups the majority of the prohibitions into four sets

of questions addressing internal program operations and two sets of questions addressing external

relationships. The topics covered are:

Internal Program Operations

Equal opportunity to benefit

Reasonable program modifications

Surcharges and additional requirements

Integrated settings and separate programs

External Relationships

Contracting with external organizations

Licensing and certification

NOTE: Whenever a question is not applicable, please note N/A


ADA TRANSITION PLAN

Department/Office:___________________________________Division/Section:____________________________

Worksheet Completed by:____________________________Tel:__________________Date:___________________

Location

List all facilities or other locations where the program operates on a regular or incidental basis. (Use additional sheets

if necessary)

Description of Program

Describe the purpose, scope, type of activities, number and type of participants, and other key information about the

program (or attach existing descriptive information).

Sign-off: Program Manager:________________________________________Date:__________________________

ADA Specialist:________________________________________________Date:________________________

INTERNAL PROGRAM OPERATIONS

Equal Opportunity to Participate and Benefit

a) A public entity may not deny a qualified individual with a disability an opportunity to participate in and

benefit from any program. (Example: A public library may not refuse to allow a person with a cognitive

disability the use of library facilities.)

b) A public entity may not afford an opportunity that is not equal to or not as effective as that provided to others.

(Example: A public recreation facility may not restrict the hours during which people with limited vision

may use the facility to be less than the hours open to the general public.)

c) A public entity may not impose eligibility criteria for participation in programs that screen out people with

disabilities either directly or indirectly, unless such criteria are necessary for the provision of the program’s

activities. (Example: A scuba diving class cannot exclude people who use wheelchairs based on the

assumption that people who use wheelchairs cannot swim well enough. However, the scuba class may require

that all participants pass a swimming test if swimming is needed for safe participation in the class.)

Are there any circumstances in which the participation of a person with a disability in the program would be restricted

or excluded?

If so, please describe.


ADA TRANSITION PLAN

Are any of these exclusions or restrictions necessary to the operation of the program or to the safety of the participants

who do not have disabilities?

Is so, please explain.

Sign-off: Program Manager:____________________________________Date:___________________________

ADA Specialist:________________________________________________Date:____________________________

Reasonable Program Modifications

Public entities are required to make reasonable modifications to policies or practices in order to avoid discrimination

towards people with disabilities. A modification is not required, however, if it would fundamentally alter the nature

of the program or activity.

Is staff aware that it may be necessary to modify program policies or practices to enable people with disabilities to

participate in and benefit from the program?


Does the program have a formal or informal process for responding to request for modifications?


Does the program have a process for determining whether a policy or practice modification would fundamentally alter

the nature of the program?


Surcharges and Additional Requirements

Public entities may not impose extra charges upon people with disabilities to cover the costs of effective

communication, program modifications, or access features, and may not impose any additional requirements or

burdens on people with disabilities that they do not require of all other participants in the program. (Example: A public

park may not require that a person with a disability bring a person assistant in order to participate in a recreational

program.)


ADA TRANSITION PLAN

Are there any circumstances in which a person with a disability would be asked to pay a fee or meet an other

requirement not imposed on other program participants?


Sign-off: Program Manager:______________________________________Date:____________________________

ADA Specialist:______________________________________________Date:___________________________

Integrated Settings and Separate Programs

Promoting integration is fundamental principle of the ADA and public entities are required to provide programs and

activities in the most integrated settings appropriate to the needs of people with disabilities.

Separate programs or activates are permitted only when necessary to ensure equal opportunity. When separate

programs are provided, qualified people with disabilities still cannot be excluded from participating in regular

programs if they choose to do so. (Example: A county recreation program offers a swimming session once a week in

which volunteer instructors provide individualized assistance to people with physical disabilities. People with physical

disabilities may choose to participate in the assisted program or in the regular swim sessions where no individual

assistance is provided.)

Does the program provide any separate activities for people with disabilities?

If yes, please describe how the separate activity contributes to affording people with disabilities an equal opportunity

to benefit.

Are there any circumstances in which a person with a disability would be prohibited from participating in regular

(non-separate) activities because of the provision of separate activities?

If yes, please describe.


ADA TRANSITION PLAN

Sign-off: Program Manager:__________________________________________Date:_______________________

ADA Specialist:____________________________________________________Date:_______________________

EXTERNAL REALATIONSHIPS

Contracting with External Organizations

When a public entity contracts with another organization to provide programs and services to the entity’s constituents

the public entity retains responsibility for ensuring that the contractor provides the services and activities in a

nondiscriminatory manner consistent with the requirements of Title II.

List any contractors who provide services, benefits, or activities on behalf of the program (or attach separate sheet if

necessary).

Has the program notified each contractor of its responsibilities for providing contracted services in a nondiscriminatory

manner and has the program required assurance from contractors of their fulfillment of Title II nondiscrimination and

access requirement?

If so, please describe both the notification process and the process by which the entity will ensure compliance.

Procurement Contracts

In selecting procurement contractor, a public entity may not discriminate on the basis of disability. (Example: A food

supplier could not be denied a contract to supply the entity’s cafeteria because a delivery person has AIDS.)

Are there any circumstances in which a consideration related to disability would influence the choice of a procurement

contractor?

If so, please explain.


ADA TRANSITION PLAN

Sign-off: Program Manager:__________________________________________Date:________________________

ADA Specialist___________________________________________________Date:_______________________

Licensing and Certification

Public entities may not deny a license or certification to any person with a disability who meets the essential eligibility

requirements for that license or certification. Eligibility requirements cannot include criteria that directly or indirectly

screen out people with disabilities unless the criteria are necessary to the performance of the activity which is the

object of the license or certification.

List any license or certifications that the program issues.

List any eligibility criteria that may tend to screen out people with disabilities-for example, criteria related to physical

or mental fitness or performance, safety standards, or insurability requirements.

For each potentially exclusionary criterion, identify how the criterion is necessary to the performance of the activity

to which the license or certificate applies.

Sign-off: Program Manager____________________________________________Date:_____________________

ADA Specialist:_____________________________________________________Date:____________________


ADA TRANSITION PLAN

Attachment IV: Communications Access Survey


ADA TRANSITION PLAN

AMERICANS WITH DISABILITIES ACT

COMMUNICATION ACCESS SURVEY

Human Resource Department

Title II of the Americans with Disabilities Act requires Governmental entities to provide effective

means of communication to people with visual, hearing, speech, and cognitive disabilities. The

purpose of this survey is to assess the County’s ability to provide communication for persons with

disabilities that is as effective as the communication provided to persons who do not have

disabilities. The information collected in this survey will allow the Human Resource Department

to generate a summary of existing communication resources throughout the County and establish

procedures for optimum sharing.


ADA TRANSITION PLAN

Department/Office:_________________________________Division/Section:_____________________________

Worksheet Completed by:___________________________Telephone:_______________Date:______________

Assess the current ability of the programs, services and activities to provide communication for persons with

disabilities that are as effective as the communication provided to persons who do not have disabilities.

Visual Communication

Information that is communicated visually-such as through printed materials or visual displays-must be made

accessible, upon request, to people with visual disabilities through auxiliary aids and services.

Does your operation involve information that is communicated visually? Yes No

In the chart below, list each type of information that is communicated visually. Consider all aspects of the program,

including, but not limited to outreach, advertising, public meetings, or hearings, ceremonies, and communication with

the general public, applicants, and other program participants. Examples may include brochures, forms, handbooks,

textbooks, slide shows, videotapes, and visual displays.

For each type of information, place an X below the auxiliary aids or service currently available to people with visual

disabilities.

Types of

Information

Large

Print

Braille

Audiotape

Readers

Verbal

Descriptions

Computer

Disk

Computer

Adaption

Other

Communication Access

Auxiliary Aids or Services


ADA TRANSITION PLAN

Aural/Oral Communication

(Note “Aural” refers to information that is heard; “Oral” refers to spoken information.)

Departments, Offices, Divisions, and Sections that communicate information aurally to applicants or participants or

that require an applicant or participant to use oral communication must make that information accessible to the people

who have hearing or speech disabilities by providing auxiliary aids and services.

Does your operation involve information that is communicated verbally? Yes No

In the chart below, list each type of information that is communicated aurally/orally. Consider all communication

involved in all aspects of the program activities. Consider all aspects of the operation, including but not limited to,

outreach, advertising, public meetings or hearings, interviews, counseling, ceremonies, and communication with the

general public, applicants, and other participants. For instance, a variety of interpreters may be needed, from American

Sign Language interpreters to oral interpreters for people who read lips or special interpreters for deaf-blind persons.

For each type of information, place an X below the auxiliary aids or services currently available to people with hearing

or speech disabilities.

Types of

Information

Interpreter

Assistive

Listening

Devices

Telephone

Amplification

Note

Takers

Paper

&

Pen

CART (real time)

Caption

Decoder

Other

Auxiliary Aids or Services


ADA TRANSITION PLAN

Primary Consideration

Title II’s regulations require that public entities provide people with disabilities an opportunity to request the type of

communication technology and assistance they prefer to use. In the ADA regulations, communication technology and

assistance are called auxiliary aids and services.

An entity must give primary consideration to an individual’s preference for an auxiliary aid or service and must honor

it unless the entity can provide another effective means of communication.

Does the program inform people with disabilities communication aids are or services are provided upon request?

Yes No

If so, please explain.

Does the program have a procedure for deciding which auxiliary aid or service to provide? Yes No

Does the procedure provide for consideration of an individual’s preferred aid or service? Yes No

Does the procedure include a mechanism for determining that an aid or service provided other than the requested aid

or service is an effective means of communication? Yes No

If the answer to any of these three questions is yes, please describe and/or attach procedure.

Telephone Communications

When a public entity communicates with the public by telephone, Title II requires that Telecommunication Device for

the Deaf (TDD) or equally effective means is used to communicate with people who have hearing or speech

disabilities. Title IV of the ADA mandates that telephone companies develop telephone relay systems, which may be

effective for short, uncomplicated communications. Public entities should use TDD’s wherever telephone

communication is substantial part of a program’s operation. Your answers to the following questions will help

determine whether a TDD may be essential for your program.

Does the program communicate with the public over the phone? Yes No

What kind of information is communicated by phone?

Communication Access


ADA TRANSITION PLAN

Are telephone communications ever lengthy, complex, or technical? Yes No

Does the program have a TTY? Yes No

If so, has the staff been trained in the use of the TTY? Yes No

Please describe training:

Emergency Warning and Evacuation

Emergency evacuation procedures for the program, service, or activity must ensure that people with disabilities are

made aware of emergencies and are aware of exit procedures.

Is there a means of ensuring that people who are hard of hearing or deaf are made aware of an activated alarm?

Yes No

Is there an established emergency evacuation procedure that addresses the needs of individuals with disabilities?

Yes No

If yes, provide a copy of the procedure.

If no, please describe the procedures the program will use in facilities where means of egress are not accessible to

provide safety and evacuation for people who cannot use stairs.

Do staff members receive training in emergency evacuation procedures? Yes No

Please describe.

Access Information

The Title II regulation requires public entities ensure people with disabilities can obtain information about the

availability and location of accessible programs, services, activities, and facilities. Information regarding location of

accessible entrances, program sites, TTY’s and other access features can be provided in a number of ways, such as in

handbooks listings.

Explain how your program, service, or activity provides access information to applicants, participants, and the general

public.

Other Communication


ADA TRANSITION PLAN

Attachment V: ADA Coordinator Job Description


ADA TRANSITION PLAN

EL PASO COUNTY

JOB DESCRIPTION

ADA COORDINATOR

Human Resources

Summary of Position

The Americans with Disabilities Act (ADA) Coordinator serves as the principal planning

coordinator for El Paso County programs, policies, and procedures relating to county compliance

and the promotion of opportunities for persons with disabilities in the community.

Organizational Relationships

Reports to: HR Director or designee

Directs: This is a non supervisory position; however, may oversee and direct the work of

contractors.

Other: Has frequent contact with: Elected Officials/Department heads, Attorney’s,

state and federal agencies, other county employees and the general public.


ADA TRANSITION PLAN

Essential Duties

Coordinates El Paso County programs and responsibilities to assure compliance with the ADA,

Sections 503 and 504 of the Rehabilitation Act of 1973, and other federal laws and regulations

pertaining to persons with disabilities;

Serves as the principal planning coordinator for El Paso County ADA accessibility and facilities

compliance programs, tracks progress of policies and procedures relating to county, state, and

federal laws in compliance and the promotion of county opportunities for persons with

disabilities;

Conducts an evaluation of facilities and accessibility and creates a formal transition plan with

concrete timelines for all programs, services, and activities. Consults with various county offices

to give and receive feedback during the phases of the evaluation and transition plan as required

under 28 C.F.R. § 38.150;

Refers employment related ADA complaints to the Human Resources Department;

Addresses modifications to policies and practices that exclude or limit participation of

individuals with disabilities in programs, services, and activities;

Ensures that effective communication systems are used to communicate with ADA

individuals regarding programs, services, and activities and ensures that county employees

are familiar with policies and practices for full participation of individuals with disabilities;

Designs presentations for county employees of the provision of equal opportunity for persons

with disabilities;

Ensures individuals with mobility impairments are provided access to public meetings;

Develops and maintains written materials and other informational pieces to broadly disseminate

information regarding the ADA and the county policies relating to persons with disabilities;

Ensures and reviews the construction of each new facility or part of a facility for barriers

that limit the accessibility of its programs, services, and activities to persons with disabilities

and conforms to the standards designated under Title II regulations;

Develops procedures for evacuation of persons with disabilities during an emergency;

Develops and implements internal measures and/or reports which inform the county

administration of the status of ADA accessibility compliance and opportunities for people with

disabilities in a timely manner;

Coordinates with the departments on non-employment related complaints alleging discrimination

and non-compliance under the ADA and other applicable federal and state laws regarding

discrimination on the basis of disability;


ADA TRANSITION PLAN

Maintains a record of accessibility and accommodation issues and the resolution of each;

Provides consultative services among all the various county offices, departments and El Paso

community to serve as the central intake for County non-employment matters relating to the

ADA, Texas Accessibility Standards (TAS) facilities activity, and the flow of information;

Serves as primary liaison with relevant state and federal agencies, as well as other ADA

coordinators at colleague institutions and associations;

Maintains current information regarding state and federal laws and regulations as well as best

practices of other entities concerning the rights of persons with disabilities and ways of providing

reasonable accommodations to persons with disabilities while maintaining program performance

standards;

Plans and designs phases of modifications on a quarterly basis of the current and following quarter

to ensure that county-related information is readily available on services, accommodations,

policies and demographics relating to persons with disabilities;

Provides the policy statement and grievance procedure to all County employees concerning

accessibility for the disabled and offers training to County employees so that people with

disabilities are treated in a nondiscriminatory manner and are afforded the same service as that

afforded any citizen;

Ensures that appropriate processes are in place to provide for the prompt and equitable resolution

of complaints and inquiries from the public regarding discrimination on the basis of disability;

Knows all specific grievance procedures and procedures for requests for accommodations under

Title II of the ADA; develops and posts written policy statement indicating the County’s ADA

policy; makes the policy statement and grievance procedures available to members of the public

on request; and online;

Attends seminar(s) concerning a public entity’s obligations under Title II of the ADA, the

Architectural Barriers Act Accessibility Guidelines (ADAAG) and the TAS and thereafter

annually and other training as directed;

Commits self to providing excellent customer service and demonstrate commitment through

cooperative team and individual efforts;

Creates a high quality work culture through participation in and emphasis on training and

mentoring to develop leadership, management, and technical skills in self and all employees,

including safety related training and skills.


ADA TRANSITION PLAN

Other Important Duties*

Within six (6) months of hire, the ADA Coordinator(s) will attend seminar(s) concerning a public

entity’s obligations under Title II of the ADA, the ADAAG and the TAS. If no such classes are

available for the TAS, the ADA Coordinator will attend the TAS training within six (6) months of

the resumption of such training; Attends sensitivity training (e.g. how to address people with

disabilities, how to accommodate people with disabilities, etc.).

Attends similar educational seminar(s) annually.

As members of the County of El Paso Emergency Response System, all El Paso County

employees are designated as Disaster Service Workers during a proclaimed emergency and may

be required to train on emergency response and/or perform certain emergency services at the

direction of their supervisor.

Performs such other related duties as may be assigned.

Minimum Requirements: Knowledge, Skills, and Abilities

Knowledge of: ADA, ADAAG, and TAS; construction, equipment, and work station modifications

which may be used to provide accessibility and reasonable accommodation to the public; project

management; County Capital Budget process; principles and practices of training and program

evaluation; English usage, grammar, punctuation and spelling; techniques for effective

interpersonal communications; modern office procedures, methods and computer equipment to

include Windows and Microsoft based products. Skill/Ability to: facilitate the resolutions of public

grievances and complaints relative to ADA; negotiate; train; complete projects on time and within

budget; operate personal computer using standard Office operating software and general office

equipment; communicate effectively both orally and in writing; make mathematical computations;

prepare clear, concise and comprehensive written reports; and establish and maintain cooperative

and effective relationships with those contacted during the course of work.

Each and every county position requires the following professional skills and abilities as key and

necessary elements of performance:

Demonstrate regular and reliable attendance;

Work well with others and participate fully in a team oriented environment;

Interface with other employees and customers in a courteous and respectful manner;

Maintain strict confidentiality;

Project positive support of their department and all county organizations at all times; and,

Maintain and enhance the County’s commitment to customer service excellence


ADA TRANSITION PLAN

Acceptable Experience and Education

Graduation from an accredited four-year college or university with major course work in public or

business administration, construction technology, or a related field; and four (4) years’ experience

in developing and implementing accessibility-based compliance and accommodation programs

mandated by federal and State laws, including ADA;

Or any equivalent combination of experience and training which provides the required knowledge,

skills, and abilities.

Certificates and Licenses Required

Must have or obtain by date of hire Texas driver's license applicable to job responsibilities, with a

driving record acceptable to the County of El Paso

Physical Demands

While performing the duties of this job, the employee is regularly required to use hands and fingers,

to handle, or feel; reach with hands and arms; and talk or hear. The employee frequently is required

to sit. The employee is occasionally required to stand; walk; climb or balance; and stoop, kneel,

crouch, or crawl. The employee must frequently lift and/or move up to 10 pounds and occasionally

lift and/or move up to 25 pounds. Specific vision abilities required by this job include ability to

adjust focus.

Work Environment

Office environment and field work. While performing the duties of this job, the employee is

occasionally exposed to outside weather conditions. The noise level in the work environment is

usually moderate.

The above is intended to describe the general nature and level of work being performed by

this position. The statements are not intended to be an exhaustive list of all responsibilities

and duties required of personnel so classified.

Job Location (Place(s) where work is performed)

Various locations through the County

Equipment (Machines, tools, etc., used in job performance)

Computer

Various office equipment

Calculator

Various software applications

Other equipment related to job performance


ADA TRANSITION PLAN

THE COUNTY OF EL PASO, TEXAS

PHYSICAL REQUIREMENTS AND CONDITIONS

Physical Requirement Degree

Hearing Acuity: low/average/sharp

Visual Acuity: rough/average/precision

Visual Color Acuity low/average/high

Manual Dexterity: To accomplish duties as stated

in job description

Operate Moving Equipment: no/yes

Operate Vehicles: Uses county vehicle or own vehicle for

business travel

Environment: office/field

Extremes: low/average/high

Noise: low/average/high

Chemicals: low/average/high

Confined Space: low/average/high

Heights: low/average/high


ADA TRANSITION PLAN

Uneven Terrain: low/average/high

Other Special Physical Requirements: Ability to communicate orally and in

written form

standard of the evaluation of applicants for positions in the job classification and in reviewing the capabilities

and physical restriction of employees returning from Industrial and Illness Leaves of Absence.

In an 8-hour workday an employee can be expected to:

(Note: Rare = 1-10% Occ.=11-33% Freq.=34-66% Cont.=67-100%)

On the Job You: Never Rare Occ. Freq. Cont.

Bend/Stoop X

Squat X

Crawl X

Climb X

Reach above shoulder level X

Crouch X

Kneel X

Sit X

Push/Pull X

Weight limitations: Indicate frequency (Never, Occ. Freq., Cont.)

Active/lbs 0-10 11-24 25-34 35-50 51-74 75 -100 >100

Lifting FREQ. OCC. OCC. OCC. NEVER NEVER NEVER

Carrying FREQ. OCC. OCC. OCC. NEVER NEVER NEVER

Push/Pull FREQ. OCC. OCC. OCC. NEVER NEVER NEVER


ADA TRANSITION PLAN

Approved:

Elected Official/Department Head Date

____________________________________________ ______________

Chief Human Resources Officer Date

History:

08/01/2011- Commissioners Court approved - Item #26 – new position created

Civil Service approval: 09/06/2011, Item #9

11/01/2017 Change FLSA Status to Exempt.

_____________________________ ________________________________,

_________________

Received by: Print Name Signature Date

____________________________

Department


ADA TRANSITION PLAN

Attachment VI: Grievance Procedures


ADA TRANSITION PLAN

THE COUNTY OF EL PASO

Grievance Procedure under

the Americans with Disabilities Act

Grievances Regarding Physical Access:

This Grievance Procedure is established to meet the requirements of Title II of the Americans

with Disabilities Act of 1990 ("ADA"). It may be used by anyone who wishes to file a complaint

alleging discrimination on the basis of disability in the provision of services, activities, programs,

or benefits by El Paso County.

The grievance may be in writing as provided for on the El Paso County ADA Grievance Form,

and contain information about the alleged discrimination such as name, address, phone

number of the grievant and location, date, and description of the problem. Alternative means

of filing grievances, such as personal interviews or a tape recording of the grievant will be

made available for persons with disabilities upon request.

The grievance should be submitted by the grievant and/or his/her designee as soon as

possible but no later than sixty (60) business days after the alleged violation to the:

ADA Coordinator

800 E. Overland Suite 223

El Paso, Texas 79901

(915) 546-2218; Fax (915) 546-8126

Within fifteen (15) business days after receipt of the grievance, the County ADA Coordinator or

designee will make all reasonable efforts to meet with the grievant to discuss the grievance and

the possible resolutions. Within fifteen (15) business days of the meeting, County ADA

Coordinator or designee will respond in writing, and where appropriate, in a format accessible to

the grievant, such as large print, Braille, or audio tape. The response will explain the position of

El Paso County and offer options for substantive resolution of the grievance.


ADA TRANSITION PLAN

Grievances Regarding Program Activity Participation or Receipt of County Services:

The grievance should be submitted by the grievant and/or his/her designee as soon as

possible but no later than ten (10) business days after the alleged violation to the:

ADA Coordinator

800 E. Overland Suite 223


(915) 546-2218; Fax (915) 546-8126

Within five (5) business days after receipt of the grievance, the County ADA Coordinator or

designee will make all reasonable efforts to meet with the grievant to discuss the grievance and

the possible resolutions. Within five (5) business days of the meeting, County ADA Coordinator

or designee will respond in writing, and where appropriate, in a format accessible to the grievant,

such as large print, Braille, or audio tape. The response will explain the position of El Paso County

and offer options for substantive resolution of the grievance.

Appeal of Grievances Regarding Physical Access, Program Activity Participation, or

Receipt of County Services:

If the response by County ADA Coordinator or designee does not satisfactorily resolve the

grievance, the grievant and/or his/her designee may notify County ADA Coordinator or designee

that they intend to appeal the decision.

Within ten (10) business days after receipt of the notice of the appeal, County ADA Coordinator

or designee places an item on the agenda of the El Paso County Commissioners Court. In the

event the subject of the grievance is of a sensitive nature as determined by the Commissioners

Court, the Commissioners Court shall table the item for one week, and the Commissioners Court

shall designate two members of the Commissioners Court to meet with the El Paso County ADA

Coordinator or designee (Collectively known as the Grievance Committee) and the Grievant to

resolve the issue(s) if possible. The Grievance Committee shall then forward the resolution to the

Commissioners Court in a timely fashion. The El Paso County Commissioners Court will respond

in writing, and, where appropriate, in a format accessible to the grievant, with a final resolution of

the grievance.

Grievances Regarding Employment Practices:

All grievances regarding alleged discrimination by El Paso County on the basis of disability in the

hiring or employment practices under Title I of the Americans with Disabilities Act of 1990 (“ADA”)

are addressed by the procedures in the El Paso County Civil Service Rules and Regulations, or

the El Paso County Employee Handbook. Any grievances regarding discrimination in hiring or

employment practices should be submitted to the:


ADA TRANSITION PLAN

County Human Resources Director

800 E. Overland, Room 223


(915) 546-2218; Fax (915) 546-8126

Grievance Record Retention Policy:

All written grievances received by El Paso County, appeals to the El Paso County Commissioners

Court, and responses from these offices will be retained by El Paso County for at least three

years.


ADA TRANSITION PLAN

Attachment VII: Reasonable Accommodations Request


ADA TRANSITION PLAN

AMERICANS WITH DISABILITIES ACT GRIEVANCE FORM FOR

ACCESS/PARTICIPATION IN FACILITIES, PROGRAMS, SERVICES, AND

BENEFITS

Today's Date:

Name of Grievant:

Address of Grievant:

Telephone Number of Grievant:

Name, Address, and Telephone Number of Grievant’s Representative:

1. Agency alleged to have denied

access:

Department:

Location:

I was denied access on: [date]

2. Disability Statement:

My disability is:

This problem is: temporary________

permanent________

3. I am seeking access to the following El Paso County facility __, program __,

activity__, service__, or benefit__, in which I haven't been able to participate

because I need an accommodation or modification:

4. Please describe the particular way in which you believe you have been denied

participation in any facility, service, program, or activity or have otherwise been

subjected to discrimination. Please specify dates, times, and places of incidents,

and names and/or positions of agency employees involved, if any, as well as

names, addresses and telephone numbers of any eyewitnesses to any such

incident. Attach additional pages if necessary. 5. Proposed Access or Accommodation:

Describe the way in which you feel participation may be accomplished to the

benefits described above, or the way in which accommodation could be provided to

allow access:


ADA TRANSITION PLAN

Deliver, Mail, or Fax this form to: ADA Coordinator

800 E. Overland, Suite 223


915.546.2218 (Phone)

915.546.8126 (Fax)


ADA TRANSITION PLAN

Attachment VIII: Reasonable Modifications


ADA TRANSITION PLAN

AMERICANS WITH DISABILITIES ACT GRIEVANCE FORM FOR

ACCOMODATION IN EMPLOYMENT

Today's Date:

Name of Grievant:

Address of Grievant:

Telephone Number of Grievant:

Name, Address, and Telephone Number of Grievant’s Representative:

1. Agency alleged to have denied

access:

Department:

Location:

I was denied access on: [date]

2. Disability Statement:

My disability is:

This problem is: temporary________

permanent________

3. I am seeking making a complaint regarding the following El Paso County

employment policies: application procedures __, hiring __, firing__,

advancement__, compensation__, job training __, or other terms, conditions, and

privileges of employment ___, which occurred due to my disability:

4. Please describe the particular way in which you believe you have been

discriminated against as a qualified individual with a disability in any terms,

conditions, or privileges of employment. Please specify dates, times, and places of

incidents, and names and/or positions of agency employees involved, if any, as well

as names, addresses and telephone numbers of any eyewitnesses to any such

incident. Attach additional pages if necessary. 5. Proposed Reasonable Access or Accommodation:

Describe the way in which you feel an accommodation could be provided to

alleviate the discrimination which you are alleging:


ADA TRANSITION PLAN

Deliver, Mail, or Fax this form to: County Human Resources Director

800 E. Overland, Room 223


(915) 546-2218; Fax (915) 546-8126


ADA TRANSITION PLAN

Attachment IX: Notice under Americans with Disabilities

Act


ADA TRANSITION PLAN

EL PASO COUNTY

NOTICE UNDER THE AMERICANS WITH DISABILITIES ACT

In accordance with the requirements of Title II of the Americans with Disabilities Act of 1990 ("ADA"),

El Paso County will not discriminate against qualified individuals with disabilities on the basis of

disability in its services, programs, or activities.

Employment: El Paso County does not discriminate on the basis of disability in its hiring or

employment practices and complies with all regulations promulgated by the U.S. Equal

Employment Opportunity Commission under Title I of the ADA.

Effective Communication: El Paso County will generally, upon request, provide appropriate

aids and services leading to effective communication for qualified persons with disabilities so they

can participate equally in El Paso County’s programs, services, and activities, including qualified

sign language interpreters, documents in Braille, and other ways of making information and

communications accessible to people who have speech, hearing, or vision impairments.

Modifications to Policies and Procedures: El Paso County will make all reasonable

modifications to policies and programs to ensure that people with disabilities have an equal

opportunity to enjoy all of its programs, services, and activities. For example, individuals with

service animals are welcomed in El Paso County offices, even where pets are generally

prohibited.

Anyone who requires an auxiliary aid or service for effective communication, or a modification of

policies or procedures to participate in a program, service, or activity of El Paso County, should

contact the ADA Coordinator at 800 E. Overland, Suite 223, El Paso Texas 79901; (915) 546-

2218; Fax. (915) 546-8126, as soon as possible, but no later than 48 hours before the scheduled

event.

The ADA does not require the El Paso County to take any action that would fundamentally alter

the nature of its programs or services, or impose an undue financial or administrative burden.

Complaints that a program, service, or activity of El Paso County is not accessible to persons

with disabilities should be directed to the, ADA Coordinator at 800 E. Overland, Suite 223, El Paso

Texas 79901; (915) 546-2218; Fax. (915) 546-8126.

El Paso County will not place a surcharge on a particular individual with a disability or any group

of individuals with disabilities to cover the cost of providing auxiliary aids/services or reasonable

modifications of policy, such as retrieving items from locations that are open to the public but are

not accessible to persons who use wheelchairs.


ADA TRANSITION PLAN

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